2012 (5) TMI 836

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....the revenue has challenged the impugned order of the Ld. CIT (A)-18 Mumbai dated 31.08.2010 for the A.Y. 2007-08. The revenue has taken the following effective ground: "1. On the facts and in the circumstances of the case and in law the Ld. CIT (A) erred in deleting the addition made on account of deemed dividend u/s.2(22)(e) of the I.T. Act amounting to ₹ 65,98,007/-." 2. The issue in co....

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....the Directors were holding more than 10% shares in M/s. Yashm Chemphor Pvt. Ltd. and more than 20% shares in the assessee company, which has received loan from M/s. Yashm Chemphor Pvt. Ltd. In the opinion of the A.O. the amount of loan taken from M/s. Yashm Chemphor Pvt. Ltd. was taxable in the hands of the assessee-company as a deemed dividend u/s.2(22)(e) of the Act as in both the companies, the....