- (1.) Heard Sri Shubham Agrawal, learned Counsel for the appellant.
(2.) As the controversy involved in both these appeals is identical, therefore, both the appeals are being heard and decided by a common judgement and order treating this appeal as a leading case.
(3.) This is an appeal filed by the revenue under Section 260-A of the Income Tax Act, 1961 against an order of the Income Tax Appellate Tribunal dated 24.05.2012 for the assessment year 2007-08. The question of law sought to be answered are hereunder:- "1. Whether the ITAT was correct in law in deleting the addition made on account of deemed dividend u/s 2 (22) (e) of I.T. Act, 1961 by treating the transaction between the assessee company and M/s Treadstone Ltd as Commercial/Trade transaction and not loan and advances, particularly when such a transaction is defined as deemed dividend u/s 2(22) (e).";