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    <title>2016 (3) TMI 741 - ITAT MUMBAI</title>
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    <description>The Tribunal allowed the appeal, deleting the addition made under section 2(22)(e) of the Income-tax Act regarding deemed dividend. The Tribunal held that without accumulated profits from earlier years, the provision of deemed dividend could not be applied to the current year&#039;s profits. Consequently, the addition made by the AO was deemed unsustainable on merits. The issue of the validity of reopening of assessment proceedings was not adjudicated as the addition on merits was deleted, and the appeal was treated as allowed.</description>
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      <title>2016 (3) TMI 741 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=325557</link>
      <description>The Tribunal allowed the appeal, deleting the addition made under section 2(22)(e) of the Income-tax Act regarding deemed dividend. The Tribunal held that without accumulated profits from earlier years, the provision of deemed dividend could not be applied to the current year&#039;s profits. Consequently, the addition made by the AO was deemed unsustainable on merits. The issue of the validity of reopening of assessment proceedings was not adjudicated as the addition on merits was deleted, and the appeal was treated as allowed.</description>
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      <pubDate>Fri, 15 Jan 2016 00:00:00 +0530</pubDate>
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