2015 (8) TMI 1261

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....ining to assessment year 2003-04. 2. In this appeal, the assessee has raised the following grounds of appeal:- "1. Against addition of Rs. 905,515/- as deemed dividend U/S 2(22)(e) of the Income-tax Act, 1961 (Act). The Commissioner of Income-tax (Appeals) -17, Mumbai [hereinafter referred to as CIT (A)] has erred in upholding the addition of Rs. 905,515/ - made by the Assessing Officer ('AO') u/s 2(22)(e) of the Act ignoring the facts of the case. The CIT (A) should have appreciated that the said amount represents following: a. Rs. 900,000/- being repayment of loan advanced by the appellant to Tainwala Trading and Investment Co. Pvt. Ltd. (TTIC) on 1st April 2009. b. Rs. 5,515/- being rental i....

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.... as at 31st March 2010. The appellant humbly prays that the impugned addition made by the CIT(A) be deleted, in the interest of natural justice." 2. The appellant before us is a company incorporated under the provisions of the Companies Act, 1956 and is inter-alia, engaged in the business of investment in movable and immovable assets and buying, selling, marketing and dealing in all kinds of fashion products and commission agency. For the year under consideration it filed a return of income,declaring an income of Rs. 10,25,26,780/- which was subject to scrutiny assessment, wherein the total income was determined at Rs. 10,65,59,300/-. The addition made to the returned income, and which is subject matter of controversy before us, is an....