2020 (3) TMI 1301

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.... May 2012 passed by the learned CITI(A) in the matter of assessment under section 143(3) of the Income Tax Act, 1961, for the assessment year 2008-09. 2. In first and second ground of appeal, which we will take up together, the Assessing Officer has raised grievance against the learned CIT(A) deleting the addition of Rs. 5,47,903 made under section 2(22)(e) of the Act. 3. So far as this disallo....

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.... person from the money is received is a shareholder of the assessee company, deemed dividend under section 2(22)(e), even if embedded in such receipts, cannot be taxed in the hands of the assessee. The Assessing Officer is aggrieved and is in appeal before us. 4. We have heard the rival contentions, perused the material on record and duly considered facts of the case and the applicable legal po....