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    <title>2005 (4) TMI 10 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>The proposed loan from an Indian company to a UK company was held not to be &quot;deemed dividend&quot; under section 2(22)(e) of the Income-tax Act, 1961. The ruling authority found that the loan did not meet the conditions required for it to be considered as such, as the shareholder did not have substantial interest in the borrower, and the loan was not for the individual benefit of the shareholder. Consequently, questions regarding the assessment entity and tax rate were deemed moot. The ruling was made by the Authority for Advance Rulings on April 6, 2005.</description>
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      <link>https://www.taxtmi.com/caselaws?id=6582</link>
      <description>The proposed loan from an Indian company to a UK company was held not to be &quot;deemed dividend&quot; under section 2(22)(e) of the Income-tax Act, 1961. The ruling authority found that the loan did not meet the conditions required for it to be considered as such, as the shareholder did not have substantial interest in the borrower, and the loan was not for the individual benefit of the shareholder. Consequently, questions regarding the assessment entity and tax rate were deemed moot. The ruling was made by the Authority for Advance Rulings on April 6, 2005.</description>
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