DCIT v. Forum Projects (P.) Ltd. (2023) 202 ITD 51 (Kol) (Trib.)

S. 2(22)(e) : Deemed dividend-Advances from companies-Substantial shareholding-Lending money is the business-Advances cannot be assessed as deemed dividend.

Held that the assessee had received advances from two companies in which assessee had substantial shareholding, since both transactions with aforesaid concerns were business and commercial arrangements duly supported not only by agreements but also by conduct of parties involved, said advances could not be treated as deemed dividend under section 2(22).(AY. 2010-11 to 2012-13)