https://www.taxtmi.com/caselaws?id=23756 The court ruled in favor of the assessee, stating that section 2(22)(e) of the Income-tax Act was not applicable as the payments made to the assessee's sons were not deemed dividends. The court found that the Revenue failed to prove that the gifts were made on behalf of or for the benefit of the assessee. Additionally, the court held that the burden of proof was on the Revenue, which they did not discharge. The judgment favored the assessee, and the case was forwarded to the Income-tax Appellate Tribunal, Cochin Bench. en-us Sat, 02 Sep 1989 00:00:00 +0530 Sun, 02 May 2010 23:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=23756 The court ruled in favor of the assessee, stating that section 2(22)(e) of the Income-tax Act was not applicable as the payments made to the assessee's sons were not deemed dividends. The court found that the Revenue failed to prove that the gifts were made on behalf of or for the benefit of the assessee. Additionally, the court held that the burden of proof was on the Revenue, which they did not discharge. The judgment favored the assessee, and the case was forwarded to the Income-tax Appellate Tribunal, Cochin Bench. Case-Laws Income Tax Sat, 02 Sep 1989 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=23756