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    <title>2021 (12) TMI 397 - ITAT DELHI</title>
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    <description>The Tribunal allowed the appeals, ruling that the provisions of section 2(22)(e) of the Income Tax Act were not applicable in the case where the assessee received a loan from a company for working capital needs related to export orders. The Tribunal considered legal precedents and commercial nature of the transaction, concluding that the loan did not fall under section 2(22)(e). As a result, the addition of the loan amount was not upheld, and both appeals of the assessee were allowed.</description>
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      <description>The Tribunal allowed the appeals, ruling that the provisions of section 2(22)(e) of the Income Tax Act were not applicable in the case where the assessee received a loan from a company for working capital needs related to export orders. The Tribunal considered legal precedents and commercial nature of the transaction, concluding that the loan did not fall under section 2(22)(e). As a result, the addition of the loan amount was not upheld, and both appeals of the assessee were allowed.</description>
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