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The HC upheld the application of deemed dividend provisions under Section 2(22)(e) where the advance granted by the company to the shareholder was not utilized for executing any business transaction. The court emphasized that exclusion from deemed dividend treatment requires proof that the advance was actually used for business purposes, not merely given for such purposes. The Assessee's admission that the advance was used to pay Income-tax under KVSS, rather than for job work, confirmed the advance's classification as deemed dividend. Repayment within the same financial year or maintenance of running accounts and ongoing business transactions did not negate this conclusion. Concurrent factual findings across multiple orders were affirmed, and the HC declined to interfere under appellate jurisdiction, ruling in favor of the Revenue.
The HC upheld the application of deemed dividend provisions under Section 2(22)(e) where the advance granted by the company to the shareholder was not utilized for executing any business transaction. The court emphasized that exclusion from deemed dividend treatment requires proof that the advance was actually used for business purposes, not merely given for such purposes. The Assessee's admission that the advance was used to pay Income-tax under KVSS, rather than for job work, confirmed the advance's classification as deemed dividend. Repayment within the same financial year or maintenance of running accounts and ongoing business transactions did not negate this conclusion. Concurrent factual findings across multiple orders were affirmed, and the HC declined to interfere under appellate jurisdiction, ruling in favor of the Revenue.
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