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Therefore respectfully following the judgments of Hon'ble Apex Court as mentioned above we are of the view that Ld. CIT (A) has rightly confirmed the disallowance of ROC fees incurred exclusively for increase in share capital. No interference is therefore called for in the finding of Ld. CIT (A).

Shanti Prime Publication Pvt. Ltd.

Section 2(22) of the Income Tax Act, 1961 — Deemed Dividend — Assessee holding company received advance from its subsidiary company for making strategic investments in real estate projects being purely in nature of trade. advance received in ordinary course of business as per agreed Memorandum of Understanding was a commercial transaction, hence, not deemed dividend under section 2(22)(e)— Asian Business Connections P. Ltd. vs. Deputy Commissioner of income tax [2019] 179 ITD 595 (Indore-trib)

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