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    <title>2025 (12) TMI 419 - ITAT AHMEDABAD</title>
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    <description>ITAT AHMEDABAD allowed the assessee&#039;s appeal, deleting the addition made as &quot;deemed dividend&quot; u/s 2(22)(e). The Tribunal held that the impugned loan/advance was given by the assessee company to its sister concern and not to a shareholder who is a beneficial owner of shares holding at least 10% voting power, nor to a concern in which such shareholder had substantial interest. As the statutory preconditions of s. 2(22)(e) were not satisfied, the transaction could not be treated as deemed dividend. Reliance on Ankitech precedent was held inapplicable on these facts.</description>
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      <title>2025 (12) TMI 419 - ITAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=782879</link>
      <description>ITAT AHMEDABAD allowed the assessee&#039;s appeal, deleting the addition made as &quot;deemed dividend&quot; u/s 2(22)(e). The Tribunal held that the impugned loan/advance was given by the assessee company to its sister concern and not to a shareholder who is a beneficial owner of shares holding at least 10% voting power, nor to a concern in which such shareholder had substantial interest. As the statutory preconditions of s. 2(22)(e) were not satisfied, the transaction could not be treated as deemed dividend. Reliance on Ankitech precedent was held inapplicable on these facts.</description>
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