https://www.taxtmi.com/caselaws?id=448672 ITAT Delhi held that advances from a company to a shareholder carrying interest charges do not constitute deemed dividend under section 2(22)(e). The tribunal found that interest-bearing advances with TDS deductions reflected a quid pro quo arrangement benefiting the lender company, establishing business character rather than personal benefit to the shareholder. Following precedents from Calcutta HC and Gujarat HC, the tribunal concluded such transactions fall outside the deeming fiction of section 2(22)(e) since they serve business purposes rather than individual shareholder benefit. The assessee's appeal was allowed. en-us Fri, 19 Jan 2024 00:00:00 +0530 Sat, 27 Jan 2024 08:31:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=448672 ITAT Delhi held that advances from a company to a shareholder carrying interest charges do not constitute deemed dividend under section 2(22)(e). The tribunal found that interest-bearing advances with TDS deductions reflected a quid pro quo arrangement benefiting the lender company, establishing business character rather than personal benefit to the shareholder. Following precedents from Calcutta HC and Gujarat HC, the tribunal concluded such transactions fall outside the deeming fiction of section 2(22)(e) since they serve business purposes rather than individual shareholder benefit. The assessee's appeal was allowed. Case-Laws Income Tax Fri, 19 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=448672