https://www.taxtmi.com/caselaws?id=206132 For applying s. 2(22)(e) of the IT Act to alleged deemed dividend where shares of a closely held company were acquired for a partnership firm but held in partners' names, the HC held that the partnership firm, being the beneficial owner, must be treated as the "shareholder" for the provision. The court reasoned that insisting on registered membership would permit easy avoidance by recording only some partners' names and thereby frustrating the disclosure object underlying s. 187C of the Companies Act. Consequently, it was unnecessary that the firm be a registered shareholder in the company's records to attract s. 2(22)(e), and the claim of non-taxability was rejected. en-us Mon, 11 Jul 2011 00:00:00 +0530 Tue, 23 Dec 2025 14:43:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=206132 For applying s. 2(22)(e) of the IT Act to alleged deemed dividend where shares of a closely held company were acquired for a partnership firm but held in partners' names, the HC held that the partnership firm, being the beneficial owner, must be treated as the "shareholder" for the provision. The court reasoned that insisting on registered membership would permit easy avoidance by recording only some partners' names and thereby frustrating the disclosure object underlying s. 187C of the Companies Act. Consequently, it was unnecessary that the firm be a registered shareholder in the company's records to attract s. 2(22)(e), and the claim of non-taxability was rejected. Case-Laws Income Tax Mon, 11 Jul 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=206132