Loans from Subsidiary to Holding Company not Deemed Dividend u/s 2(22)(e) When Transactions are Part of Consistent Business Practice: ITAT [Read Order]

The Tribunal, however, noted that there was no dispute about the corporate relationship or the receipt of the loan.
Loans-Subsidiary -Holding - Company - taxscan

In a recent ruling, the Income Tax Appellate Tribunal ( ITAT ) Kolkata Bench has held that loans received by a holding company from its subsidiary cannot be taxed as deemed dividend under Section 2(22)(e) of the Income Tax Act, 1961, when such transactions are part of a consistent business practice and are duly disclosed….

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