https://www.taxtmi.com/caselaws?id=760060 ITAT Delhi dismissed revenue's appeal on two grounds. First, regarding addition under section 14A read with rule 8D, the tribunal upheld CIT(A)'s deletion of disallowance since assessee declared no exempt income during the year, following precedent in PCIT vs. Era Infrastructure case. Second, on deemed dividend addition under section 2(22)(e), the tribunal agreed with CIT(A) that advances between assessee and wholly owned subsidiary constituted current revenue transactions for traveling and conveyance expenses rather than loan transactions, thus not qualifying as deemed dividend. en-us Fri, 11 Oct 2024 00:00:00 +0530 Tue, 15 Oct 2024 08:39:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=760060 ITAT Delhi dismissed revenue's appeal on two grounds. First, regarding addition under section 14A read with rule 8D, the tribunal upheld CIT(A)'s deletion of disallowance since assessee declared no exempt income during the year, following precedent in PCIT vs. Era Infrastructure case. Second, on deemed dividend addition under section 2(22)(e), the tribunal agreed with CIT(A) that advances between assessee and wholly owned subsidiary constituted current revenue transactions for traveling and conveyance expenses rather than loan transactions, thus not qualifying as deemed dividend. Case-Laws Income Tax Fri, 11 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=760060