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    <title>2019 (7) TMI 1596 - ITAT CHENNAI</title>
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    <description>The Tribunal dismissed the appeal, upholding the addition of deemed dividend under Sec.2(22)(e) of the Act. The appellant&#039;s argument that funds were received for commercial expediency was rejected due to lack of authorization from the company&#039;s Board of Directors. The Tribunal found no new facts to distinguish the case from previous decisions, supporting the Commissioner&#039;s findings. The appellant&#039;s reliance on a Calcutta High Court judgment was deemed irrelevant as no evidence proved the amounts were for specific services. The decision stressed the significance of factual evidence and precedent in tax matters, affirming the Commissioner&#039;s decision.</description>
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      <title>2019 (7) TMI 1596 - ITAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=287278</link>
      <description>The Tribunal dismissed the appeal, upholding the addition of deemed dividend under Sec.2(22)(e) of the Act. The appellant&#039;s argument that funds were received for commercial expediency was rejected due to lack of authorization from the company&#039;s Board of Directors. The Tribunal found no new facts to distinguish the case from previous decisions, supporting the Commissioner&#039;s findings. The appellant&#039;s reliance on a Calcutta High Court judgment was deemed irrelevant as no evidence proved the amounts were for specific services. The decision stressed the significance of factual evidence and precedent in tax matters, affirming the Commissioner&#039;s decision.</description>
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