https://www.taxtmi.com/caselaws?id=208958 The High Court dismissed the Revenue's appeal in a case involving deemed dividends under Section 2(22)(e) of the Income Tax Act. The court held that the provision applies to shareholders or concerns with substantial interest, not non-shareholders like the assessee-company. Since the assessee did not hold the required shares in the lending companies, the additions of deemed dividends were deemed inapplicable. The judgment emphasized the importance of shareholder status in determining tax liability under the provision and clarified that legal fiction does not extend to non-shareholders in such cases. en-us Mon, 21 Nov 2011 00:00:00 +0530 Fri, 23 Dec 2011 11:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208958 The High Court dismissed the Revenue's appeal in a case involving deemed dividends under Section 2(22)(e) of the Income Tax Act. The court held that the provision applies to shareholders or concerns with substantial interest, not non-shareholders like the assessee-company. Since the assessee did not hold the required shares in the lending companies, the additions of deemed dividends were deemed inapplicable. The judgment emphasized the importance of shareholder status in determining tax liability under the provision and clarified that legal fiction does not extend to non-shareholders in such cases. Case-Laws Income Tax Mon, 21 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208958