https://www.taxtmi.com/caselaws?id=768810 The ITAT Jaipur held that addition under section 2(22)(e) was not sustainable where money received by assessee from company account originated from bank loan sanctioned in assessee's name with company as co-applicant. The tribunal found that since disbursement was not from company's accumulated profits but from bank loan where assessee was primary applicant, deemed dividend provisions under section 2(22)(e) were not applicable. The reassessment was based on Internal Audit Party observations of transactions already on record, not on incriminating material found during search. The tribunal deleted the entire addition, rejecting CIT(A)'s partial sustenance to extent of accumulated profits. Assessee's appeal was allowed. en-us Fri, 11 Apr 2025 00:00:00 +0530 Mon, 14 Apr 2025 08:36:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=768810 The ITAT Jaipur held that addition under section 2(22)(e) was not sustainable where money received by assessee from company account originated from bank loan sanctioned in assessee's name with company as co-applicant. The tribunal found that since disbursement was not from company's accumulated profits but from bank loan where assessee was primary applicant, deemed dividend provisions under section 2(22)(e) were not applicable. The reassessment was based on Internal Audit Party observations of transactions already on record, not on incriminating material found during search. The tribunal deleted the entire addition, rejecting CIT(A)'s partial sustenance to extent of accumulated profits. Assessee's appeal was allowed. Case-Laws Income Tax Fri, 11 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=768810