https://www.taxtmi.com/highlights?id=57086 Deemed dividend u/s.2(22)(e) - The provisions of section 2(22)(e) of the Act, is a deeming provision and should be construed strictly. It is an established fact that the said transaction took place during the course of business and there being no personal/individual benefit accrued to the assessee and hence section 2(22)(e) of the Act cannot be invoked. Had it been the case of the AO that the assessee had directly borrowed loans and advances from the company to his proprietorship concern, then the AO could have invoked the provisions of section 2(22)(e) of the Act. - AT en-us Tue, 09 Mar 2021 18:04:47 +0530 Tue, 09 Mar 2021 18:04:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=57086 Deemed dividend u/s.2(22)(e) - The provisions of section 2(22)(e) of the Act, is a deeming provision and should be construed strictly. It is an established fact that the said transaction took place during the course of business and there being no personal/individual benefit accrued to the assessee and hence section 2(22)(e) of the Act cannot be invoked. Had it been the case of the AO that the assessee had directly borrowed loans and advances from the company to his proprietorship concern, then the AO could have invoked the provisions of section 2(22)(e) of the Act. - AT Highlights Income Tax Tue, 09 Mar 2021 18:04:47 +0530 https://www.taxtmi.com/highlights?id=57086