https://www.taxtmi.com/caselaws?id=772852 The ITAT Mumbai dismissed the assessee's appeal regarding deemed dividend under section 2(22)(e). The assessee received loans/advances from another company where they held substantial shareholding in both entities. The Tribunal distinguished between loans and deposits, noting loans create immediate repayment obligations while deposits have contingent obligations. The assessee failed to provide evidence supporting the transaction as an inter-corporate deposit, including absence of interest provisions, TDS details, or proper documentation. The unexplained routing through a third party raised questions about transaction bonafides. The advance was deemed for securing the assessee's investment benefit, thus not qualifying for deemed dividend exceptions. en-us Mon, 19 May 2025 00:00:00 +0530 Sat, 14 Jun 2025 06:47:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772852 The ITAT Mumbai dismissed the assessee's appeal regarding deemed dividend under section 2(22)(e). The assessee received loans/advances from another company where they held substantial shareholding in both entities. The Tribunal distinguished between loans and deposits, noting loans create immediate repayment obligations while deposits have contingent obligations. The assessee failed to provide evidence supporting the transaction as an inter-corporate deposit, including absence of interest provisions, TDS details, or proper documentation. The unexplained routing through a third party raised questions about transaction bonafides. The advance was deemed for securing the assessee's investment benefit, thus not qualifying for deemed dividend exceptions. Case-Laws Income Tax Mon, 19 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772852