https://www.taxtmi.com/caselaws?id=186853 The High Court affirmed the decisions of the lower authorities, ruling that the Respondent Assessee Company, not being a shareholder of M/s Rajrani Exports Private Limited, was not liable for deemed dividend under Section 2(22)(e) of the Income Tax Act, 1961. The court emphasized that the concept of "shareholder" in this provision does not encompass entities that are not direct shareholders of the paying company. Thus, the appeal was dismissed, clarifying that the legal fiction of deemed dividend does not extend to non-shareholders. en-us Mon, 24 Jun 2013 00:00:00 +0530 Thu, 03 Aug 2017 08:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=186853 The High Court affirmed the decisions of the lower authorities, ruling that the Respondent Assessee Company, not being a shareholder of M/s Rajrani Exports Private Limited, was not liable for deemed dividend under Section 2(22)(e) of the Income Tax Act, 1961. The court emphasized that the concept of "shareholder" in this provision does not encompass entities that are not direct shareholders of the paying company. Thus, the appeal was dismissed, clarifying that the legal fiction of deemed dividend does not extend to non-shareholders. Case-Laws Income Tax Mon, 24 Jun 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=186853