https://www.taxtmi.com/caselaws?id=781329 ITAT MUMBAI - AT held that loans sanctioned by a closely held company to a >10% shareholder who was its managing director constituted deemed dividend under s.2(22)(e), rejecting the employee-benefit and ordinary-course-of-business defenses because the scheme was newly instituted with the director as first beneficiary and lending was not a substantial part of the company's business; CBDT Circular guidance was inapplicable. Separately, deductions claimed against consultancy receipts were disallowed under s.57 for lack of cogent evidence of nexus. Both grounds of appeal were dismissed. en-us Thu, 28 Aug 2025 00:00:00 +0530 Fri, 14 Nov 2025 09:42:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781329 ITAT MUMBAI - AT held that loans sanctioned by a closely held company to a >10% shareholder who was its managing director constituted deemed dividend under s.2(22)(e), rejecting the employee-benefit and ordinary-course-of-business defenses because the scheme was newly instituted with the director as first beneficiary and lending was not a substantial part of the company's business; CBDT Circular guidance was inapplicable. Separately, deductions claimed against consultancy receipts were disallowed under s.57 for lack of cogent evidence of nexus. Both grounds of appeal were dismissed. Case-Laws Income Tax Thu, 28 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781329