https://www.taxtmi.com/caselaws?id=790421 Amounts received from a sister concern for software testing and development in the ordinary course of business were not treated as deemed dividend under Section 2(22)(e) of the Income-tax Act, 1961. The factual record showed that the payments were made for commercial services and were later adjusted against bills raised by the assessee, indicating a trade transaction rather than a loan or advance. The court also relied on the settled principle that trade advances arising from genuine business dealings fall outside deemed dividend, consistent with CBDT Circular No. 19/2017 clarifying that Section 2(22)(e) does not apply to commercial transactions. en-us Tue, 20 Jan 2026 00:00:00 +0530 Fri, 24 Apr 2026 08:52:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790421 Amounts received from a sister concern for software testing and development in the ordinary course of business were not treated as deemed dividend under Section 2(22)(e) of the Income-tax Act, 1961. The factual record showed that the payments were made for commercial services and were later adjusted against bills raised by the assessee, indicating a trade transaction rather than a loan or advance. The court also relied on the settled principle that trade advances arising from genuine business dealings fall outside deemed dividend, consistent with CBDT Circular No. 19/2017 clarifying that Section 2(22)(e) does not apply to commercial transactions. Case-Laws Income Tax Tue, 20 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790421