Held that transaction is purchase of property for the purpose of business of Company M/s SCPL and it cannot be called as a gratuitous loan or advance given by the Company to the assessee, that it is a pure business transaction. Addition is deleted. (AY. 2013-14)
Jitendra Kapildeo Gupta v. DCIT (2022) 64 CCH 359/ 216 TTJ 751 / 212 DTR 71 (Pune)(Trib.)/ACIT v. Subu Chem (P) Ltd( 2022) / 216 TTJ 751 / 212 DTR 71 (Pune)(Trib.)
S. 2(22)(e) : Deemed dividend-Finance company-Advance loan-Not assessable as deemed dividend.