2023 (2) TMI 87

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....A CHANDRA, JUDICIAL MEMBER For the Assessee : Shri Satish Agarwal, CA Shri Dharender Kumar, CA Shri Rachit Agarwal, CA For the Department : Shri Vivek Vardhan, Sr. DR ORDER PER N. K. BILLAIYA, ACCOUNTANT MEMBER : - This appeal by the Revenue and Cross Objections by the assessee are preferred against the order of the ld. CIT(A) - 7, New Delhi dated 16.05.2018 pertaining to Assessment....

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.... dividend. 5. In its reply, the assessee stated that it has provided a corporate guarantee to PNB in arrangement in 2010 and Riello agreed to provide PCI [the assessee] an interest bearing loan of Rs. 5 crores as and when required. It was explained that loan arrangement was business arrangement and outside the purview of deemed dividend. 6. In support of its submissions, the assessee furnish....

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.... 8. The assessee carried the matter before the ld. CIT(A) and reiterated what has been stated in the assessment proceedings. 9. The ld. CIT(A), after considering the facts and submissions, found that the assessee had furnished a confirmation from M/s RPS SPA, Italy, the parent of present M/s Riello and a copy of board resolution passed by the assessee wherein the board had resolved to furnish ....

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....nd Based Facilities of Rs 5.00 crores and Non-funbased facilities of Rs. 5.00 crores. Respective limits of M/s PCI Ltd. be reduced by equivalent amount. Company to arrange NOC from Canara Bank for creating our 1st/1sl paripassu charge all the existing collaterals available in the A/c of M/s PCI Ltd and there should be on of collateral security available to the bank." The credit f....