Deemed Dividends u/s 2(22) of Income Tax Act: Capital Nature Questioned; Section 46(2) Inapplicable.

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....Addition u/s 2(22) - Deemed dividend - the amount in the nature of capital or not - dividend was declared before liquidation and dividend distribution tax was paid u/s. 115-O of the Act by the company (dividend was declared on 05.07.1999 and dividend distribution tax was paid on 31.01.2001). Therefore, the provisions of section 46(2) of the Act do not have application to the facts of the present case. - AT....