2017 (2) TMI 511

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....ng following substantial question of law:- "Whether on the facts and in the circumstances of the case, the Tribunal is right in law in holding that the addition made under section 2(22)(e) of the Act on the amount paid to the assessee firm by the company M/s. NSPL, could not be assessed as 'deemed dividend' in the hands of the assessee-firm even when all the ingredients of the said provis....