https://www.taxtmi.com/caselaws?id=293507 Section 2(22)(e) deemed dividend applies only where the payment is received by a shareholder of the payer company. The ITAT Ahmedabad followed the jurisdictional High Court view, consistent with the Delhi High Court, that the deeming fiction cannot be extended to a recipient company that is not itself the shareholder from whom the payment was made, even if the amount may otherwise represent accumulated profits. On that basis, the addition under section 2(22)(e) was deleted and the Revenue's appeal failed. en-us Thu, 12 Mar 2020 00:00:00 +0530 Sat, 13 Feb 2021 21:49:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=293507 Section 2(22)(e) deemed dividend applies only where the payment is received by a shareholder of the payer company. The ITAT Ahmedabad followed the jurisdictional High Court view, consistent with the Delhi High Court, that the deeming fiction cannot be extended to a recipient company that is not itself the shareholder from whom the payment was made, even if the amount may otherwise represent accumulated profits. On that basis, the addition under section 2(22)(e) was deleted and the Revenue's appeal failed. Case-Laws Income Tax Thu, 12 Mar 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=293507