Dispute over Deemed Dividends: Assessing Officer's Oversight of Prior Year Loans Raises Legitimacy Questions u/s 2(22)(e.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Deemed dividend addition u/s 2(22)(e) - Provisions of Section 2(22)(e) relating to loan or advance can be deemed as dividend only to the extent of accumulated profit or so far as the loan is not reflected in the accounts, but in instance case the addition was made on the basis of the prior year amounts which was not at all discussed by the Assessing Officer as well as CIT(A) as to how the said amount was taken in respect of the current year account for making addition. - AT....