https://www.taxtmi.com/caselaws?id=465840 Issue concerns whether intercompany credits arising from a personal security and reciprocal current account transactions attract treatment as deemed dividends under Section 2(22)(e). The analysis finds the payments arose from provision of personal guarantee and routine current account interest/commission between related entities, supported by evidentiary records; accordingly the deemed dividend classification is inapplicable and the credits are taxable as commission/interest, leading to deletion of the impugned addition and partial allowance of the appeal. The decision applies consistent treatment on identical facts in earlier tribunal orders relied upon as precedent. en-us Fri, 27 Sep 2013 00:00:00 +0530 Tue, 13 Jan 2026 10:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465840 Issue concerns whether intercompany credits arising from a personal security and reciprocal current account transactions attract treatment as deemed dividends under Section 2(22)(e). The analysis finds the payments arose from provision of personal guarantee and routine current account interest/commission between related entities, supported by evidentiary records; accordingly the deemed dividend classification is inapplicable and the credits are taxable as commission/interest, leading to deletion of the impugned addition and partial allowance of the appeal. The decision applies consistent treatment on identical facts in earlier tribunal orders relied upon as precedent. Case-Laws Income Tax Fri, 27 Sep 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465840