https://www.taxtmi.com/caselaws?id=358334 The Tribunal dismissed all eight appeals of the Revenue, affirming that deemed dividend provisions under section 2(22)(e) do not apply if the recipient is not a shareholder of the lender company. Shareholders not directly receiving loans cannot be taxed under section 2(22)(e). Protective assessments under section 147 are not sustainable if they imply probable rather than confirmed escapement of income. en-us Mon, 02 Apr 2018 00:00:00 +0530 Tue, 10 Apr 2018 08:26:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358334 The Tribunal dismissed all eight appeals of the Revenue, affirming that deemed dividend provisions under section 2(22)(e) do not apply if the recipient is not a shareholder of the lender company. Shareholders not directly receiving loans cannot be taxed under section 2(22)(e). Protective assessments under section 147 are not sustainable if they imply probable rather than confirmed escapement of income. Case-Laws Income Tax Mon, 02 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358334