https://www.taxtmi.com/caselaws?id=468340 A firm could not be taxed as deemed dividend under section 2(22)(e) because it was neither the registered nor beneficial shareholder of the lending company, and common shareholding through related persons was insufficient; the addition was deleted. The Commissioner (Appeals) was entitled under section 251(1)(a) to examine the true character of the receipt already on record and to enhance the assessment, so that appellate power was upheld. A receipt under a joint development arrangement over stock-in-trade was not taxable as business income in the year under appeal because the transaction remained contingent on later regulatory approvals and the licence to enter and develop was granted only subsequently; the business income addition was deleted. en-us Wed, 08 May 2013 00:00:00 +0530 Wed, 29 Apr 2026 15:49:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468340 A firm could not be taxed as deemed dividend under section 2(22)(e) because it was neither the registered nor beneficial shareholder of the lending company, and common shareholding through related persons was insufficient; the addition was deleted. The Commissioner (Appeals) was entitled under section 251(1)(a) to examine the true character of the receipt already on record and to enhance the assessment, so that appellate power was upheld. A receipt under a joint development arrangement over stock-in-trade was not taxable as business income in the year under appeal because the transaction remained contingent on later regulatory approvals and the licence to enter and develop was granted only subsequently; the business income addition was deleted. Case-Laws Income Tax Wed, 08 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468340