Section 2(22)(e) covers only direct benefit received by the shareholder from any payment made by the company, and not indirect benefit derived from any other transaction.
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Recently, Banglore ITAT has held that section 2(22)(e) covers only direct benefit received by the shareholder from any payment made by the company, and not indirect benefit derived from any other transaction. Further, the section can apply only in the year in which the payment is made by the company, otherwise it would be not possible to ascertain the accumulated profit, and the computation mechanism will fail.
The case details is as under:
Bangalore Tribunal in Haris Kalandan Mohammed v. DCIT (ITA No.878/Bang/2024), dated 09.08.2024.
The copy of the order is as under:
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