https://www.taxtmi.com/caselaws?id=178293 Section 2(22)(e) of the Income-tax Act, 1961 cannot be applied to treat a loan as deemed dividend in the hands of a company that is not itself a shareholder of the lending company, even where the two companies have a common individual shareholder. The Tribunal's deletion of the addition was upheld by following the jurisdictional High Court ruling in Ankitech, which recognises that common shareholding alone does not satisfy the shareholder requirement for this deeming provision. On that basis, no substantial question of law arose under section 260A, and the Revenue's appeal was dismissed. en-us Mon, 16 Apr 2012 00:00:00 +0530 Fri, 30 Jun 2017 19:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=178293 Section 2(22)(e) of the Income-tax Act, 1961 cannot be applied to treat a loan as deemed dividend in the hands of a company that is not itself a shareholder of the lending company, even where the two companies have a common individual shareholder. The Tribunal's deletion of the addition was upheld by following the jurisdictional High Court ruling in Ankitech, which recognises that common shareholding alone does not satisfy the shareholder requirement for this deeming provision. On that basis, no substantial question of law arose under section 260A, and the Revenue's appeal was dismissed. Case-Laws Income Tax Mon, 16 Apr 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=178293