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    <title>2014 (12) TMI 442 - ALLAHABAD HIGH COURT</title>
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    <description>The High Court dismissed the appeal under Section 260A of the Income Tax Act, 1961, regarding the addition of a deemed dividend to the assessee&#039;s total income. The court held that the exclusionary clause (ii) of Section 2(22)(e) did not apply as the lending activity was not a substantial part of the lending companies&#039; business. Since the assessee received loans exclusively from these companies and the lending was not a significant aspect of their operations, the court upheld the Assessing Officer&#039;s decision to treat the loan as deemed dividend.</description>
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    <pubDate>Tue, 09 Dec 2014 00:00:00 +0530</pubDate>
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      <title>2014 (12) TMI 442 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=254098</link>
      <description>The High Court dismissed the appeal under Section 260A of the Income Tax Act, 1961, regarding the addition of a deemed dividend to the assessee&#039;s total income. The court held that the exclusionary clause (ii) of Section 2(22)(e) did not apply as the lending activity was not a substantial part of the lending companies&#039; business. Since the assessee received loans exclusively from these companies and the lending was not a significant aspect of their operations, the court upheld the Assessing Officer&#039;s decision to treat the loan as deemed dividend.</description>
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      <pubDate>Tue, 09 Dec 2014 00:00:00 +0530</pubDate>
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