2019 (1) TMI 1793

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....g Counsel For the Respondent : Mr.R.Sivaraman JUDGMENT (Delivered by T.S.Sivagnanam, J.) This appeal, by the Revenue filed under Section 260A of the Income-tax Act, 1961 (hereinafter referred to as "the Act"), is directed against the order of the Income-tax Appellate Tribunal, Chennai Bench 'C', Chennai (Tribunal), in I.T.A.No.1825/Mds/2008, dated 11.09.2009, for the assessment....

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.... Commissioner of Income-tax (Appeals)-III, Chennai (for brevity "the CIT(A)"), dated 28.05.2008, as well as the impugned order passed by the Tribunal, we find that the entire dispute is purely factual. 5.The question is whether the amount of Rs. 4,16,12,082/- is to be construed as a deemed dividend under Section 2(22)(e) of the Act. We find that this issue was threadbare analysed by the CIT(A) ....