2011 (9) TMI 752

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....antial questions of law having arisen out of the order passed by learned Income Tax Appellate Tribunal, Chandigarh (for short the 'Tribunal') on 18.8.2010: -  "1.  Whether on the facts and in law, the Hon'ble ITAT was legally justified in dismissing the appeal of the department and upholding the order of CIT(Appeals) in deleting the addition of Rs. 99,10,000/- made under Section 2(22)(e....

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....y Tribunal. 3. Learned Tribunal has found that in terms of Section 2(22)(e) of the Act, the dividend income is assessable only in the hands of shareholders of the lending company. It has been found that assessee is not a shareholder of M/s Ankur Agro Pvt. Ltd. Thus, the said amount cannot be assessed in the hands of the assessee in terms of Section 2(22)(e) of the Act. 4. Learned counsel for the....