IT SECTION 2(22)e

[shamji bhanushali]

Sir,

my client is partnership firm and there are 7 partners in the firm. they have one another p.ltd company. and directors are common except two partners. they are doing same business . separately.. during the year 2012-13 p.ltd Company has given Loans or Advances to partnership firm and charge interest to partnership firm. Now Assessing Officer observed and add amount of Loan account i.e. Closing balance of Loan account as per partnership balance sheet at the time of assessment subject to Section 2(22)e . can you advise us or give any judgment pronounce by High court or suprim courte related with the same section clerification.

THANK YOU

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AI Summary

Deemed dividend treatment of corporate loans to a related partnership challenged after assessing officer added the closing loan balance under tax provision. Assessing officer treated the partnership's closing loan balance as a deemed distribution under Section 2(22)(e) after a private limited company advanced loans to the partnership; the taxpayer seeks higher court authorities on applicability where the entities share directors and operate in the same business.