https://www.taxtmi.com/caselaws?id=20618 A deemed-dividend provision applies strictly to loans or advances falling within its inclusive definition, and the statutory exclusion is unavailable unless its conditions are fully satisfied. Where the loan was repaid before the dividend declaration, the assessee could not claim the benefit of the exclusion, so the advance remained taxable as deemed dividend. A general objection based on double taxation does not override express legislative intent; relief is available only through strict compliance with the specific exception built into the statute. The commentary therefore states that no exemption arises outside the statutory exclusion. en-us Thu, 08 Oct 1992 00:00:00 +0530 Thu, 15 Mar 2018 15:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20618 A deemed-dividend provision applies strictly to loans or advances falling within its inclusive definition, and the statutory exclusion is unavailable unless its conditions are fully satisfied. Where the loan was repaid before the dividend declaration, the assessee could not claim the benefit of the exclusion, so the advance remained taxable as deemed dividend. A general objection based on double taxation does not override express legislative intent; relief is available only through strict compliance with the specific exception built into the statute. The commentary therefore states that no exemption arises outside the statutory exclusion. Case-Laws Income Tax Thu, 08 Oct 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20618