ITO v. Yashovardhan Tyagi (2020) 184 ITD 461 (Delhi)(Trib.)

S. 2(22)(e) : Deemed dividend-Loans and advances-Commercial transactions-Addition cannot be made as deemed dividend.

Dismissing the appeal of the revenue the Tribunal held that amounts are advanced to an assessee by another company for business purpose wherein both entities are having common directors and if it is in nature of a commercial transaction hence addition cannot be as deemed dividend. (AY. 2011-12)