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    <title>2025 (2) TMI 1397 - ITAT MUMBAI</title>
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    <description>Addition under the deemed dividend doctrine was contested on grounds that transfers from a closely held company were trade/commercial transactions and not loans for the shareholder&#039;s personal benefit. The tribunal noted AO&#039;s earlier record, found no procedural infirmity in admission of documents, and accepted that funds were transferred so the shareholder acted as a facilitator and fixed deposits were provided as bank security for company credit facilities. Consequently the payments were treated as commercial trade advances and not as loans or advances attractable as deemed dividend; addition was rejected.</description>
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      <description>Addition under the deemed dividend doctrine was contested on grounds that transfers from a closely held company were trade/commercial transactions and not loans for the shareholder&#039;s personal benefit. The tribunal noted AO&#039;s earlier record, found no procedural infirmity in admission of documents, and accepted that funds were transferred so the shareholder acted as a facilitator and fixed deposits were provided as bank security for company credit facilities. Consequently the payments were treated as commercial trade advances and not as loans or advances attractable as deemed dividend; addition was rejected.</description>
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