Income-tax : Where lending of money was a substantial part of business of a lending company, money given by it by way of advance or loan to assessee could not be regarded as a dividend u/s 2(22)(e)
It is not possible to give any fixed definition of the word substantial in relation to a substantial business of a company as envisaged by section 2(22)(ii); any business of a company which the company does not regard as small, trivial, or inconsequential as compared to the whole of the business is substantial business - [2010] 8 TAXMANN.COM 155 (BOM.)
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