https://www.taxtmi.com/caselaws?id=33813 HC held the firm was not a shareholder of the company, so any deemed dividend under s.2(22)(e) could not arise in the firm's hands but would arise in the hands of the individual shareholders on whose behalf payments were made. The Rs.10 lakhs was characterized as paid by way of security rather than an advance, but the court observed that since over Rs.9 lakhs had been advanced only between 7 Jan and 22 Mar 1991, it was difficult to sustain that characterization as a genuine security. en-us Mon, 17 Mar 2008 00:00:00 +0530 Tue, 09 Sep 2025 16:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=33813 HC held the firm was not a shareholder of the company, so any deemed dividend under s.2(22)(e) could not arise in the firm's hands but would arise in the hands of the individual shareholders on whose behalf payments were made. The Rs.10 lakhs was characterized as paid by way of security rather than an advance, but the court observed that since over Rs.9 lakhs had been advanced only between 7 Jan and 22 Mar 1991, it was difficult to sustain that characterization as a genuine security. Case-Laws Income Tax Mon, 17 Mar 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=33813