https://www.taxtmi.com/caselaws?id=260127 The Tribunal upheld the deletion of the penalty imposed under section 271(1)(c) for A.Y. 2006-07 related to deemed dividend u/s 2(22)(e) of a specific amount. The Tribunal concluded that the deposits received by the assessee were for letting commercial properties to the companies, not loans as treated by the AO. The explanation provided by the assessee, supported by evidence, was found to be valid, leading to the deletion of the penalty. The Tribunal emphasized the importance of evidence in penalty proceedings and clarified that the deeming fiction of section 2(22)(e) does not extend to classify property usage deposits as loans. en-us Wed, 25 Mar 2015 00:00:00 +0530 Wed, 03 Jun 2015 06:09:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=260127 The Tribunal upheld the deletion of the penalty imposed under section 271(1)(c) for A.Y. 2006-07 related to deemed dividend u/s 2(22)(e) of a specific amount. The Tribunal concluded that the deposits received by the assessee were for letting commercial properties to the companies, not loans as treated by the AO. The explanation provided by the assessee, supported by evidence, was found to be valid, leading to the deletion of the penalty. The Tribunal emphasized the importance of evidence in penalty proceedings and clarified that the deeming fiction of section 2(22)(e) does not extend to classify property usage deposits as loans. Case-Laws Income Tax Wed, 25 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=260127