https://www.taxtmi.com/caselaws?id=206078 Section 2(22)(e) creates a fiction enlarging the term "dividend" but does not change who qualifies as a shareholder; therefore a concern that is not a registered shareholder cannot be treated as having received a deemed dividend under that provision. The deeming clause applies only where an advance or loan is made to a person who is a registered shareholder and beneficial owner with requisite voting power, or to payments made for their benefit; payments proved to be trading receipts or ordinary business transactions do not attract Section 2(22)(e). The effect is to confine assessment as deemed dividend to the statutorily defined shareholder relationships. en-us Wed, 11 May 2011 00:00:00 +0530 Thu, 12 Feb 2026 17:54:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=206078 Section 2(22)(e) creates a fiction enlarging the term "dividend" but does not change who qualifies as a shareholder; therefore a concern that is not a registered shareholder cannot be treated as having received a deemed dividend under that provision. The deeming clause applies only where an advance or loan is made to a person who is a registered shareholder and beneficial owner with requisite voting power, or to payments made for their benefit; payments proved to be trading receipts or ordinary business transactions do not attract Section 2(22)(e). The effect is to confine assessment as deemed dividend to the statutorily defined shareholder relationships. Case-Laws Income Tax Wed, 11 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=206078