https://www.taxtmi.com/caselaws?id=311021 ITAT Mumbai held that deemed dividend addition u/s 2(22)(e) was not sustainable where company had accumulated losses as on relevant date. The tribunal ruled that accumulated profits must be determined as on the date immediately preceding the advance/loan, not including current year profits. Since the company had accumulated losses of Rs. 74,80,633 as on 31.03.2011, no deemed dividend could arise. The addition of Rs. 3,41,96,270 was deleted, following SC precedents in Associated Banking Corporation and Gujarat HC decision in M.B. Stockholding case. en-us Mon, 09 Jan 2023 00:00:00 +0530 Sun, 03 Dec 2023 18:52:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=311021 ITAT Mumbai held that deemed dividend addition u/s 2(22)(e) was not sustainable where company had accumulated losses as on relevant date. The tribunal ruled that accumulated profits must be determined as on the date immediately preceding the advance/loan, not including current year profits. Since the company had accumulated losses of Rs. 74,80,633 as on 31.03.2011, no deemed dividend could arise. The addition of Rs. 3,41,96,270 was deleted, following SC precedents in Associated Banking Corporation and Gujarat HC decision in M.B. Stockholding case. Case-Laws Income Tax Mon, 09 Jan 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=311021