https://www.taxtmi.com/caselaws?id=766534 ITAT Delhi dismissed revenue's appeal regarding deemed dividend addition under section 2(22)(e). The assessee LLP, converted from partnership firm, maintained running account with company where partners had substantial interest. AO treated peak credit as deemed dividend without establishing transactions were for individual shareholder benefit rather than regular business advances. CIT(A) allowed assessee's appeal noting LLP partners are not shareholders post-conversion, making deemed dividend provisions inapplicable. ITAT upheld CIT(A)'s decision, finding transactions were regular business dealings maintained for mutual benefit, not individual shareholder advantage, and AO failed to verify actual nature of payments. en-us Tue, 25 Feb 2025 00:00:00 +0530 Thu, 27 Feb 2025 08:14:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766534 ITAT Delhi dismissed revenue's appeal regarding deemed dividend addition under section 2(22)(e). The assessee LLP, converted from partnership firm, maintained running account with company where partners had substantial interest. AO treated peak credit as deemed dividend without establishing transactions were for individual shareholder benefit rather than regular business advances. CIT(A) allowed assessee's appeal noting LLP partners are not shareholders post-conversion, making deemed dividend provisions inapplicable. ITAT upheld CIT(A)'s decision, finding transactions were regular business dealings maintained for mutual benefit, not individual shareholder advantage, and AO failed to verify actual nature of payments. Case-Laws Income Tax Tue, 25 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766534