No deemed dividend if assessee transferred his shareholding before date of advancement of loan: ITAT

INCOME TAX : Where Assessing Officer made addition to assessee's income by invoking provisions of section2(22)(e) on ground that assessee was holding more than ten percent shareholding in both lender and borrower companies, in view of fact that as per annual return filed before ROC, assessee had already transferred its shareholding in borrower company to lender company before advancement of loan out of surplus funds, impugned addition was to be deleted

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