https://www.taxtmi.com/caselaws?id=256731 The HC upheld the ITAT's deletion of the addition under Section 2(22)(e) of the Act, ruling against the revenue. The court found that the revenue failed to prove the transaction was a sham to disguise a dividend. The assessee demonstrated a genuine business purpose, entering into an agreement to install machinery at its premises for job work at a discounted rate due to the company's operational difficulties. The Assessing Officer did not dispute these facts. The HC held that since business expediency was established, the advance did not qualify as deemed dividend under Section 2(22)(e). The findings were neither perverse nor arbitrary, warranting no interference. en-us Mon, 02 Feb 2015 00:00:00 +0530 Tue, 12 Aug 2025 17:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=256731 The HC upheld the ITAT's deletion of the addition under Section 2(22)(e) of the Act, ruling against the revenue. The court found that the revenue failed to prove the transaction was a sham to disguise a dividend. The assessee demonstrated a genuine business purpose, entering into an agreement to install machinery at its premises for job work at a discounted rate due to the company's operational difficulties. The Assessing Officer did not dispute these facts. The HC held that since business expediency was established, the advance did not qualify as deemed dividend under Section 2(22)(e). The findings were neither perverse nor arbitrary, warranting no interference. Case-Laws Income Tax Mon, 02 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=256731