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Payment for Cold Storage Sale Not a Loan or Dividend if MOU Cancels Deal u/s 2(22)(e) Income Tax Act.

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Full Text of the Document

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....Deemed dividend u/s 2(22)(e) - The payment of the amount in pursuance to the agreement for sale of cold storage would not by itself become loan or partake the character of loan after the agreement was cancelled and MOU signed for returning the amount - HC....