Held that the advance payment was made for Special purpose vehicle for the purpose of business. Deletion of addition is held to be justified. (AY.2013-14)
Dy. CIT v. Aalap Digital Music Pvt. Ltd. (2022) 95 ITR 22 (SN) (Delhi) (Trib.)
S. 2(22)(e) : Deemed dividend-Business transaction-Special purpose vehicle-Not shareholder in lender company-Advance for business purpose-Not assessable as deemed dividend.