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    <title>2011 (3) TMI 1441 - ITAT DELHI</title>
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    <description>The Appellate Tribunal ITAT DELHI ruled that the addition of Rs. 1,43,96,908/- as dividend u/s 2(22)(e) of the Act was not justified. The Tribunal considered the collaboration agreement between the assessee and Gururakha Plastics Pvt. Ltd., where the amount received was for developing commercial buildings, not as loans or advances. Citing relevant case laws, the Tribunal concluded that the advances for real estate development did not qualify as dividends under section 2(22)(e) of the Act. The appeal by the revenue was dismissed, emphasizing the importance of the nature and purpose of payments in tax treatment.</description>
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    <pubDate>Thu, 31 Mar 2011 00:00:00 +0530</pubDate>
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      <title>2011 (3) TMI 1441 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=212434</link>
      <description>The Appellate Tribunal ITAT DELHI ruled that the addition of Rs. 1,43,96,908/- as dividend u/s 2(22)(e) of the Act was not justified. The Tribunal considered the collaboration agreement between the assessee and Gururakha Plastics Pvt. Ltd., where the amount received was for developing commercial buildings, not as loans or advances. Citing relevant case laws, the Tribunal concluded that the advances for real estate development did not qualify as dividends under section 2(22)(e) of the Act. The appeal by the revenue was dismissed, emphasizing the importance of the nature and purpose of payments in tax treatment.</description>
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