https://www.taxtmi.com/caselaws?id=764323 ITAT Mumbai held that advances received by a company from another company where the assessee held 35% shareholding did not constitute deemed dividend under section 2(22)(e). The tribunal found that the advance was given for commercial purposes to facilitate share purchase transactions, constituting a commercial transaction rather than a gratuitous advance. Following CBDT Circular 19/2017 and Pradip Kumar Malhotra precedent, the tribunal distinguished between gratuitous advances and those given for commercial advantage. The addition made by AO was deleted and assessee's appeal was allowed. en-us Mon, 06 Jan 2025 00:00:00 +0530 Wed, 08 Jan 2025 08:37:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=764323 ITAT Mumbai held that advances received by a company from another company where the assessee held 35% shareholding did not constitute deemed dividend under section 2(22)(e). The tribunal found that the advance was given for commercial purposes to facilitate share purchase transactions, constituting a commercial transaction rather than a gratuitous advance. Following CBDT Circular 19/2017 and Pradip Kumar Malhotra precedent, the tribunal distinguished between gratuitous advances and those given for commercial advantage. The addition made by AO was deleted and assessee's appeal was allowed. Case-Laws Income Tax Mon, 06 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=764323