https://www.taxtmi.com/caselaws?id=303094 The ITAT allowed the appeal, holding that the advance received by the assessee, a resident of Canada and director of an Indian company, cannot be considered as deemed dividend under the DTAA between India and Canada. The ITAT ruled that the loan received does not meet the criteria under Article 10 of the DTAA, which defines dividends as income from shares or rights participating in profits, thereby overturning the CIT(A)'s decision to treat the advance as deemed dividend under the IT Act. en-us Fri, 25 Sep 2009 00:00:00 +0530 Mon, 04 Jul 2022 11:53:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=303094 The ITAT allowed the appeal, holding that the advance received by the assessee, a resident of Canada and director of an Indian company, cannot be considered as deemed dividend under the DTAA between India and Canada. The ITAT ruled that the loan received does not meet the criteria under Article 10 of the DTAA, which defines dividends as income from shares or rights participating in profits, thereby overturning the CIT(A)'s decision to treat the advance as deemed dividend under the IT Act. Case-Laws Income Tax Fri, 25 Sep 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=303094