percent taxation of dividend income under Article
10 thereof including on deemed dividend under Section 2(22)(e) of the Act
and the term paid ... invoking Sec.2(22)(e) of the Act.
18. We have carefully considered the rival submissions. Ostensibly, Sec.
2(22)(e) of the Act creates
addition of Rs.12,00,000/- on
account of deemed dividend u/s 2(22)(e) of the Income Tax Act, 1961.
6. That ... addition of Rs.9,01,312/- on
account of deemed dividend u/s 2(22)(e) of the Income Tax Act, 1961.
6. That
addition of
Rs.2,97,74,68,364/- made by A.O. u/s 2(22)(e) as alleged deemed
dividend.
2. That ... deemed dividend
transaction u/s 2(22)(e) of the Act and are meant to circumvent the
provisions of section 2(22)(e
account of deemed dividend u/s 2(22)(e) of the Act in an assessment
order framed u/s 153A can be made ... under identical
circumstances has upheld the addition of deemed dividend u/s 2(22)(e)
made by the AO in a block assessment
deemed dividend is not part of profit and loss account. The addition on
account of deemed dividend u/s 2(22)(e ... section 2(22)(e) The head notes of the decision read as under-
" Section 2(22) of the Income-tax Act, 1961- Deemed dividend
positive balances alone were
considered for the purpose of calculation of Deemed. Dividend.
5. The Ld.CIT(A) erred in appreciating the fact that ... fact
loan/advance which attracts the provisions of section 2(22)(e) of the
Act."
3
ITA Nos.1067, 1068, 1071 and 1072
advances while arriving at
outstanding debit balances while calculating deemed dividend u/s
2(22)(e) of the Act?
2. Whether on the facts ... made addition of
Rs.149,98,02,505/- towards deemed dividend u/s 2(22)(e) of the
Act, in respect of the alleged transactions
advances while arriving at
outstanding debit balances while calculating deemed dividend u/s
2(22)(e) of the Act?
2. Whether on the facts ... made addition of
Rs.149,98,02,505/- towards deemed dividend u/s 2(22)(e) of the
Act, in respect of the alleged transactions
clear that sub-section (e) of section 2(22) which is pari
materia with clause (e) of section 2(6A) of the Indian
Income ... also provisions of section 2(22)(e)
would not apply - Held, yes.
iii) Whether deeming provision of section
2(22)(e) as it applies
section 2(22)(e) of the Act.
35. The intention behind enacting provisions of section 2(22)(e) are that closely
held companies (i.e ... section 2(22)(e) were not attracted in assessee's case.
Section 2(22) of the Income-tax Act, 1961 Deemed dividend - Assessment year
