2025 (10) TMI 763

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.... For the Respondent : Shri Prateek Sharma, Sr. DR ORDER PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- Delay Condoned This appeal has been filed by the Assessee against the order dated 21.02.2025 passed by the Ld. ADDL/JCIT(A)-7, Mumbai ('Ld. CIT(A)' in short), under Section 250 of the Income-tax Act, 1961 ('the Act' in short), relating to the Assessment Year 2015-16. 2. The assessee has....

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....he conditions of section 2(22)(e) were not satisfied either in letter or in spirit. The impugned order is therefore bad in law, based on presumptions, and liable to be quashed in its entirety." 3. The brief facts of the case are that assessee is a private limited company engaged in the business of operating and maintaining city buses under a contractual arrangement with Jaipur City Transport Se....

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....under Section 194 of the Act on this deemed dividend. Consequently, the Assessing Officer determined that the tax was deductible on Rs. 20,00,000/-, and computed the liability u/s 201(1) and 201(1A) at Rs. 3,92,000/-. 4. Aggrieved by the order of the Assessing Officer, the assessee filed appeal before the Ld. CIT(A) who dismissed the appeal of the assessee vide an ex-parte order dated 21.02.202....

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....equired for securing vehicle loans. The Ld. AR submitted that in order to facilitate the release of funds from banks for the purchase of buses, MBOPL arranged for this margin money in the form of a short-term loan. The Ld. AR submitted that the said loan was purely temporary in nature, devoid of any intention to distribute accumulated profits, and was fully repaid within the same financial year. T....