https://www.taxtmi.com/caselaws?id=445738 ITAT Chennai dismissed both assessee and revenue appeals regarding deemed dividend under section 2(22)(e). The assessee company was neither registered nor beneficial shareholder in group concerns from which unsecured loans were obtained. Two shareholders holding 70% and 30% shares respectively were registered shareholders of lending companies. CIT(A) deleted additions, which was upheld following Madras HC precedent in Ennore Cargo Container Terminal case and Calcutta HC in Pradip Kumar Malhotra case. Regarding CIT(A)'s power for assessment reopening under section 251, ITAT held this could be examined by AO when deciding whether to reopen assessment. en-us Mon, 31 Jul 2023 00:00:00 +0530 Sat, 18 Nov 2023 13:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445738 ITAT Chennai dismissed both assessee and revenue appeals regarding deemed dividend under section 2(22)(e). The assessee company was neither registered nor beneficial shareholder in group concerns from which unsecured loans were obtained. Two shareholders holding 70% and 30% shares respectively were registered shareholders of lending companies. CIT(A) deleted additions, which was upheld following Madras HC precedent in Ennore Cargo Container Terminal case and Calcutta HC in Pradip Kumar Malhotra case. Regarding CIT(A)'s power for assessment reopening under section 251, ITAT held this could be examined by AO when deciding whether to reopen assessment. Case-Laws Income Tax Mon, 31 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445738