https://www.taxtmi.com/caselaws?id=211710 Section 2(22)(e) can apply on its substantive ingredients and is not defeated merely because the payment was made to a partnership firm that was not itself a shareholder; that question was answered for the Revenue, while the separate contention that the payment was not out of accumulated profits was remitted for reconsideration. On the long-term capital loss issue, the HC declined interference under section 260A because the record did not establish perversity and the factual inquiry was incomplete; the Tribunal's deletion of the disallowance was therefore left undisturbed. en-us Wed, 29 Feb 2012 00:00:00 +0530 Tue, 02 Jul 2013 17:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211710 Section 2(22)(e) can apply on its substantive ingredients and is not defeated merely because the payment was made to a partnership firm that was not itself a shareholder; that question was answered for the Revenue, while the separate contention that the payment was not out of accumulated profits was remitted for reconsideration. On the long-term capital loss issue, the HC declined interference under section 260A because the record did not establish perversity and the factual inquiry was incomplete; the Tribunal's deletion of the disallowance was therefore left undisturbed. Case-Laws Income Tax Wed, 29 Feb 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211710