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    <title>2012 (4) TMI 684 - PUNJAB AND HARYANA HIGH COURT</title>
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    <description>The Tribunal upheld the Commissioner of Income Tax (Appeals)&#039;s decision to delete additions of deemed dividend under Section 2(22)(e) of the Income Tax Act for Assessment Year 2007-08. The Tribunal agreed that only shareholders, not the company, can be assessed for deemed dividend. It was held that different shareholders cannot be combined to meet the Section&#039;s requirements, and as none of the shareholders held substantial interest, the conditions of Section 2(22)(e) were not fulfilled. The High Court dismissed the revenue&#039;s appeal, finding no merit as the assessee did not meet the Section&#039;s requirements, and the cited judgments were unchallenged.</description>
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    <pubDate>Thu, 19 Apr 2012 00:00:00 +0530</pubDate>
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      <title>2012 (4) TMI 684 - PUNJAB AND HARYANA HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=186106</link>
      <description>The Tribunal upheld the Commissioner of Income Tax (Appeals)&#039;s decision to delete additions of deemed dividend under Section 2(22)(e) of the Income Tax Act for Assessment Year 2007-08. The Tribunal agreed that only shareholders, not the company, can be assessed for deemed dividend. It was held that different shareholders cannot be combined to meet the Section&#039;s requirements, and as none of the shareholders held substantial interest, the conditions of Section 2(22)(e) were not fulfilled. The High Court dismissed the revenue&#039;s appeal, finding no merit as the assessee did not meet the Section&#039;s requirements, and the cited judgments were unchallenged.</description>
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      <pubDate>Thu, 19 Apr 2012 00:00:00 +0530</pubDate>
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