OMM SHREE REALCON PVT. LTD,BHUBANESWAR vs. PR.CIT-1, BHUBANESWAR
In the result, appeal of the assessee stands allowed
ITA 97/CTK/2023[2018-19]Status: DisposedITAT Cuttack28 Jun 2023AY 2018-19
Bench: Before S/Shri George Mathan, Judicial & And Rajesh Kumarassessment Year : 2018-19 Om Shree Realcon Pvt Ltd., Om Shree Realcon Pvt Ltd., Vs. Pr. Cit- Bhubaneswar Bhubaneswar-1 Plot No.418, Forest Park, 8, Forest Park, Bhubaneswar. Bhubaneswar. Pan/Gir No. Pan/Gir No.Aabco 3118 P (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri S.K.Sarangi, Ca S.K.Sarangi, Ca Revenue By : Shri M.K.Gautam, Pr. Cit (Osd) Pr. Cit (Osd) Date Of Hearing : 28 /0 06/2023 Date Of Pronouncement : 28 /0 /06/2023 O R D E R Per Bench
For Appellant: Shri S.K.Sarangi, CAFor Respondent: Shri M.K.Gautam, Pr. CIT (OSD)
Section 143(3)Section 2(22)(e)Section 263Section 68
deemed as dividend to the extent the paying company has accumulated profits, the exception being where the lending company is in the business of money lending. We have already noted satisfaction of all the required conditions in the present case, as well as of the lending companies being not in the money lending business, so that exceptions to the provision