https://www.taxtmi.com/caselaws?id=234129 The appeal was filed by the revenue against the CIT(A)'s order deleting the addition made by the AO on account of deemed dividend u/s. 2(22)(e) of the Act for the A.Y. 2005-06. The Tribunal held that since the assessee was not a shareholder of the lending companies, no addition could be made in the hands of the assessee. The Tribunal emphasized the need for judicial discipline in following higher court decisions and principles, leading to the deletion of the addition. The Tribunal clarified that loans or advances covered under section 2(22)(e) should be taxed in the hands of the shareholder, not the borrower, and upheld the decision that loans to non-shareholders cannot be taxed as deemed dividends. en-us Fri, 03 May 2013 00:00:00 +0530 Thu, 30 May 2013 05:34:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234129 The appeal was filed by the revenue against the CIT(A)'s order deleting the addition made by the AO on account of deemed dividend u/s. 2(22)(e) of the Act for the A.Y. 2005-06. The Tribunal held that since the assessee was not a shareholder of the lending companies, no addition could be made in the hands of the assessee. The Tribunal emphasized the need for judicial discipline in following higher court decisions and principles, leading to the deletion of the addition. The Tribunal clarified that loans or advances covered under section 2(22)(e) should be taxed in the hands of the shareholder, not the borrower, and upheld the decision that loans to non-shareholders cannot be taxed as deemed dividends. Case-Laws Income Tax Fri, 03 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234129