https://www.taxtmi.com/caselaws?id=233563 The ITAT Mumbai ruled in favor of the appellant, holding that loans or advances to a non-shareholder cannot be taxed as deemed dividends under section 2(22)(e) of the Act. Emphasizing the importance of judicial discipline, the ITAT emphasized that the legal fiction of deeming loans as dividends does not apply to non-shareholders. As the appellant was not a shareholder in the lending companies, the addition made by the Assessing Officer was deemed unjustified. Consequently, the ITAT deleted the addition entirely, allowing the appellant's appeal. en-us Fri, 08 Apr 2011 00:00:00 +0530 Tue, 07 May 2013 10:02:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233563 The ITAT Mumbai ruled in favor of the appellant, holding that loans or advances to a non-shareholder cannot be taxed as deemed dividends under section 2(22)(e) of the Act. Emphasizing the importance of judicial discipline, the ITAT emphasized that the legal fiction of deeming loans as dividends does not apply to non-shareholders. As the appellant was not a shareholder in the lending companies, the addition made by the Assessing Officer was deemed unjustified. Consequently, the ITAT deleted the addition entirely, allowing the appellant's appeal. Case-Laws Income Tax Fri, 08 Apr 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233563