https://www.taxtmi.com/article/detailed?id=7199 Section 2(22)(e) treats certain company payments as deemed dividend where a registered shareholder has a substantial interest in a concern; the Supreme Court held the provision applied to loans to an HUF because the Karta, who was the registered shareholder and entitled to a substantial share of HUF income, caused the HUF to be a concern in which he had substantial interest under Explanation 3. The provision is a statutory fiction requiring strict interpretation, and doubts favor the assessee; the author urges repeal on policy and administrative grounds. en-us Wed, 11 Jan 2017 07:10:05 +0530 Wed, 11 Jan 2017 07:10:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=7199 Section 2(22)(e) treats certain company payments as deemed dividend where a registered shareholder has a substantial interest in a concern; the Supreme Court held the provision applied to loans to an HUF because the Karta, who was the registered shareholder and entitled to a substantial share of HUF income, caused the HUF to be a concern in which he had substantial interest under Explanation 3. The provision is a statutory fiction requiring strict interpretation, and doubts favor the assessee; the author urges repeal on policy and administrative grounds. Articles Income Tax Wed, 11 Jan 2017 07:10:05 +0530 https://www.taxtmi.com/article/detailed?id=7199