https://www.taxtmi.com/caselaws?id=451222 ITAT Jodhpur dismissed Revenue's appeal regarding deemed dividend treatment under Section 2(22)(e). The assessee received an amount initially recorded as loan but claimed it was advance salary. AO treated it as deemed dividend citing lack of documentary evidence and absence of TDS deduction before survey date. However, ITAT found the amount was genuinely advance remuneration later adjusted with proper TDS deduction, supported by ledger entries. The tribunal emphasized that double taxation on single receipt is impermissible under law. Since no revenue loss occurred as assessee paid tax at maximum marginal rate, CIT(A)'s deletion of addition was upheld. en-us Wed, 03 Jan 2024 00:00:00 +0530 Fri, 22 Mar 2024 08:37:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451222 ITAT Jodhpur dismissed Revenue's appeal regarding deemed dividend treatment under Section 2(22)(e). The assessee received an amount initially recorded as loan but claimed it was advance salary. AO treated it as deemed dividend citing lack of documentary evidence and absence of TDS deduction before survey date. However, ITAT found the amount was genuinely advance remuneration later adjusted with proper TDS deduction, supported by ledger entries. The tribunal emphasized that double taxation on single receipt is impermissible under law. Since no revenue loss occurred as assessee paid tax at maximum marginal rate, CIT(A)'s deletion of addition was upheld. Case-Laws Income Tax Wed, 03 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451222