https://www.taxtmi.com/caselaws?id=8389 Section 2(6A)(e) of the Indian Income-tax Act, 1922 treats any advance or loan by a closely held company to a shareholder, or for the shareholder's benefit, as dividend, limited only by the company's accumulated profits. The provision refers to "any payment" and does not support limiting dividend treatment to a proportionate fraction based on shareholding. Read with the anti-evasion purpose of the clause and the structure of section 2(6A), the whole loan or advance is deemed dividend to the extent of accumulated profits, not merely 1/300th or any other shareholding-based fraction. en-us Fri, 20 Aug 1971 00:00:00 +0530 Fri, 10 Apr 2009 18:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=8389 Section 2(6A)(e) of the Indian Income-tax Act, 1922 treats any advance or loan by a closely held company to a shareholder, or for the shareholder's benefit, as dividend, limited only by the company's accumulated profits. The provision refers to "any payment" and does not support limiting dividend treatment to a proportionate fraction based on shareholding. Read with the anti-evasion purpose of the clause and the structure of section 2(6A), the whole loan or advance is deemed dividend to the extent of accumulated profits, not merely 1/300th or any other shareholding-based fraction. Case-Laws Income Tax Fri, 20 Aug 1971 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=8389