Court Rules Against Double Taxation on Deemed Dividend u/s 2(22)(e) of Income Tax Act.

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....Deemed dividend u/s 2 (22)(e) - advance made by the subsidiary company to the respondent/holding company - Obviously, the department would have been well aware of the fact that the amount of ₹ 3.00 Crores advanced by the subsidiary to its holding company, cannot be taxed twice. When such being the position, we are really surprised to see that the initiation of two separate proceedings for the same transaction is not appreciable. - HC....