Dismissing the appeal of the assessee the Tribunal held that reassessment is held to be valid . The Tribunal also held that as the assessee has not established the advance of loans to business purposes, addition as deemed dividend is held to be justified. ( AY. 2005 -06)
Empire Holdings Ltd v. Dy.CIT ( 2019) 112 taxmann.com 319 ( Chennai) (Trib)
S. 2(22)(e):Deemed dividend – Loans and advances to subsidiary – Not established the business purposes – Addition as deemed dividend is held to be valid – Reassessment is also held to be valid [ S. 147 , 148 ]