2020 (5) TMI 533

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.... VP The present appeal filed by assessee is against order of CIT(A)-1, Gurgaon dated 14.05.2015 relating to assessment year 2011-12 against order passed under section 154 of the Income-tax Act, 1961 (in short 'the Act'). 2. The assessee has raised following grounds of appeal:- 1. "That the impugned order is bad in law as well as on merits. 2. That the impugned order and pro....

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.... 234 B, 234C should have been levied. Without prejudice, the interest charged is excessive." 3. At the outset, the Ld.AR for the assessee pointed out that the issue raised in the present appeal stands squarely covered in favour of the assessee by the orders of the Tribunal in the case of related person i.e. Seema Devi Bansal in ITA No.6462/Del/2014 order dated 18.07.2018 relating to Assessment ....

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....n M/s. Arihant Agencies, Gurgaon of which the assessee was the sole proprietor. The Assessing Officer was of the view that the said advances were to be taxed in the hands of the assessee as deemed dividend u/s 2(22)(e) of the Act. The details of the payment are as under:- Sl.No. Date of payment Amount paid (Rs.) Maximum amount outstanding on the date (Rs.) 1. 30.04.2010 50,00,....

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.... there were transaction of receipt and payments itself by both the parties. The Tribunal thus addressed itself as to whether such transaction is covered in the definition of deemed dividend in the hands of the assessee u/s 2(22)(e) of the Act or not. The Tribunal held the issue to be covered by the decision of Praveen Bhimsi Chheda Shivsadan vs DCIT reported in 141 TTJ 58 against which the Hon'ble....