https://www.taxtmi.com/caselaws?id=409887 ITAT Ahmedabad dismissed the Revenue's appeal and upheld the order of CIT(A). The deletion of addition u/s 2(22)(e) was sustained, holding that deemed dividend applies only to transactions with registered shareholders, not mere beneficial shareholders. The Tribunal affirmed that no TDS was deductible on freight payments to agents of non-resident shipping companies in view of s.172, rendering disallowance u/s 40(a)(ia) unsustainable. It further upheld the assessee's claim of depreciation, interest, insurance and related car expenses, recognizing the car as a company asset, with only a 25% disallowance of depreciation and car expenses maintained. Deletion of addition for alleged under-invoicing of sales to a sister concern was also confirmed. en-us Thu, 15 Jul 2021 00:00:00 +0530 Mon, 08 Dec 2025 15:20:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=409887 ITAT Ahmedabad dismissed the Revenue's appeal and upheld the order of CIT(A). The deletion of addition u/s 2(22)(e) was sustained, holding that deemed dividend applies only to transactions with registered shareholders, not mere beneficial shareholders. The Tribunal affirmed that no TDS was deductible on freight payments to agents of non-resident shipping companies in view of s.172, rendering disallowance u/s 40(a)(ia) unsustainable. It further upheld the assessee's claim of depreciation, interest, insurance and related car expenses, recognizing the car as a company asset, with only a 25% disallowance of depreciation and car expenses maintained. Deletion of addition for alleged under-invoicing of sales to a sister concern was also confirmed. Case-Laws Income Tax Thu, 15 Jul 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=409887