https://www.taxtmi.com/caselaws?id=402868 The Tribunal dismissed the Revenue's appeals for both AY 2012-13 and AY 2013-14, affirming that the shareholding of the minor should not be included in the assessee's shareholding for the purposes of Section 2(22)(e). It was held that the deeming provisions must be strictly construed, and the assessee did not meet the criteria for deemed dividend under the said section. The Tribunal emphasized that the shares held by the minor were independently sourced and not beneficially owned by the assessee, leading to the dismissal of the appeals. en-us Thu, 17 Dec 2020 00:00:00 +0530 Thu, 14 Jan 2021 11:40:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=402868 The Tribunal dismissed the Revenue's appeals for both AY 2012-13 and AY 2013-14, affirming that the shareholding of the minor should not be included in the assessee's shareholding for the purposes of Section 2(22)(e). It was held that the deeming provisions must be strictly construed, and the assessee did not meet the criteria for deemed dividend under the said section. The Tribunal emphasized that the shares held by the minor were independently sourced and not beneficially owned by the assessee, leading to the dismissal of the appeals. Case-Laws Income Tax Thu, 17 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=402868