https://www.taxtmi.com/caselaws?id=6510 A loan or advance by a closely held company to a shareholder is deemed dividend to the extent of accumulated profits when the statutory conditions in section 2(6A)(e) read with section 12(1B) are met. The statutory fiction operates at the time of payment, and the Act does not require the loan to remain outstanding at the end of the previous year. Repayment before year-end therefore does not displace the charging provision, and the court declined to add words from an overseas analogue that the legislature had not adopted. The amount remained taxable as deemed dividend notwithstanding repayment. en-us Thu, 28 Apr 1977 00:00:00 +0530 Tue, 03 Jan 2017 16:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=6510 A loan or advance by a closely held company to a shareholder is deemed dividend to the extent of accumulated profits when the statutory conditions in section 2(6A)(e) read with section 12(1B) are met. The statutory fiction operates at the time of payment, and the Act does not require the loan to remain outstanding at the end of the previous year. Repayment before year-end therefore does not displace the charging provision, and the court declined to add words from an overseas analogue that the legislature had not adopted. The amount remained taxable as deemed dividend notwithstanding repayment. Case-Laws Income Tax Thu, 28 Apr 1977 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=6510