https://www.taxtmi.com/caselaws?id=411140 The ITAT dismissed the revenue's appeal and upheld the CIT(A)'s decision to delete the disallowance of Rs. 2,70,50,000/- made by the Assessing Officer under section 2(22)(e) of the Income Tax Act, 1961. The ITAT concluded that the deemed dividend provision under section 2(22)(e) applies only to shareholders of the lender company, and since the assessee company was not a shareholder in the lender company, the loan could not be treated as deemed dividend. en-us Mon, 16 Aug 2021 00:00:00 +0530 Wed, 18 Aug 2021 09:28:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411140 The ITAT dismissed the revenue's appeal and upheld the CIT(A)'s decision to delete the disallowance of Rs. 2,70,50,000/- made by the Assessing Officer under section 2(22)(e) of the Income Tax Act, 1961. The ITAT concluded that the deemed dividend provision under section 2(22)(e) applies only to shareholders of the lender company, and since the assessee company was not a shareholder in the lender company, the loan could not be treated as deemed dividend. Case-Laws Income Tax Mon, 16 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411140