IT : In view of provisions of section 2(22)(e), 'deemed dividend' taken together in hands of all persons cannot exceed accumulated profits of company and, therefore, where assessee, a director in two companies, took loan from those companies, in view of fact that said companies were having tax or excise liability during assessment year under consideration and as a result there were no accumulated profits in their hands in beginning of year, amount of loan taken by assessee from said companies co
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