assessee HUF and the same was treated as deemed dividend in the hands of assessee HUF Under Section 2(6A)(e) of the Indian Income ... three business concerns of the assessee could not be regarded as deemed dividend within the meaning of Section 2(6A)(e) inasmuch as the word
JGPL which
constituted ‗advances and loans' would be treated as deemed
dividend within the meaning of Section ... dividend because if so
distributed the dividend income would become taxable in the
hands of the shareholders. Instead of distributing accumulated
profits as dividend, companies
2009 Page 1
Empro Exports Pvt. Ltd. is not deemed dividend under Section 2(22)(e) of the
Act.
2. The facts of the case ... distributed as dividend, cannot be brought within the
deeming provision of treating such „Advance‟ as deemed
dividend"
10. We agree with the aforesaid observations
said amount of Rs.5.99 crores was
assessed as a deemed dividend under Section 2(22)(e) of
the said ... Assessment Order, the Department assessed the said
sum as deemed dividend in the hands of the assessee
under Section
interested may not declare dividends or adequate dividends and may merely give loans to its shareholders. Being loans and not dividends, the amounts would ... loan must be deemed to have been paid out of the "accumulated profits" and be deemed to be dividend and not having been
made Under Section 2(22)(e) as deemed dividend.
4. The assessee company (referred to as NHSL, for short) is having regular transactions with another ... advances so as to attract the deeming provisions of Section 2(22)(e) , still, the quantum of deemed dividend worked out by the assessing officer
were taken to assess the deemed dividend income in the hands of the two assessees. The ITO revised the assessments of the assessees in respect ... whole of the dividend income including the entire actual dividend income received by the assessee, as also in respect of the deemed dividend income irrespective
purchase of its own shares could not be considered as "deemed dividend", within the meaning of section ... Direct Taxes seeking their confirmation that the amount would not be deemed dividend". The Life Insurance Corporation of India and the Unit Trust
added back an amount of Rs. 1,73,750 as deemed dividend to the income of the assessee.
4. Being aggrieved, the assessee preferred ... dividend '. It does not take in dividend actually declared or received. The dividend taken note of by that provision is a deemed dividend
treated as "deemed dividends" under section 2(6A)(e) . Injregard to Steel Industries, the Income-tax Officer found that ... should be treated as "deemed dividend" under section 2(6A)(e) . The Income-tax Officer rejected the assessee's contention that
