2026 (3) TMI 1489

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.... S. Rifaur Rahman, Accountant Member For the Assessee : Shri Amit Goel, CA, Sh. Pranav Yadav, Advocate For the Revenue : Shri Mahesh Kumar, CIT (DR) ORDER PER BENCH: These twin assessee's S/Sh. Gautam Bali and Shri Deepak Sood have filed their seven appeals each i.e. ITA Nos. 5860 to 5873 /Del./2025, along with the Revenue's as many cross appeals thereto ITA Nos. 7868 to 7874/Del./2....

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....both these assessee's Shri Gautam Bali and Shri Deepak Sood hold 60 and 17% stake; respectively, in a company namely M/s. Vestige Marketing Private Limited. And that the Assessing Officer ('AO') had framed assessment in the said company's case disallowing its purchases claim of Rs. 8, 86,36,574/- as bogus ones u/s 37 of the Act in the "lead" A.Y. 2018-19. He thereafter treated 80% of the said disa....

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.... entirety. 6. We have given our thoughtful consideration to the rival submissions of both these assessee's as well as the Revenues respective stands. We find no merit in the Revenue's arguments justifying impugned deemed dividend addition. This is for the precise reason that Section 2(22)(e) of the Act itself makes it clear that the same gets attracted in an instance of "any payment by a compan....