https://www.taxtmi.com/caselaws?id=450127 The ITAT Chennai held that loans advanced by a company to assessee companies cannot be taxed as deemed dividend under section 2(22)(e) as the primary condition was not satisfied. The tribunal determined that for section 2(22)(e) to apply, the loan recipient must be a registered and beneficial shareholder holding at least 10% voting power in the lender company on the date of loan advancement. Since neither the assessee companies nor their shareholders held any shares in the lender company, and no common shareholders existed between the entities, the deemed dividend provisions were inapplicable. The tribunal upheld the CIT(A)'s deletion of additions made by the AO. en-us Wed, 21 Feb 2024 00:00:00 +0530 Tue, 27 Feb 2024 17:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450127 The ITAT Chennai held that loans advanced by a company to assessee companies cannot be taxed as deemed dividend under section 2(22)(e) as the primary condition was not satisfied. The tribunal determined that for section 2(22)(e) to apply, the loan recipient must be a registered and beneficial shareholder holding at least 10% voting power in the lender company on the date of loan advancement. Since neither the assessee companies nor their shareholders held any shares in the lender company, and no common shareholders existed between the entities, the deemed dividend provisions were inapplicable. The tribunal upheld the CIT(A)'s deletion of additions made by the AO. Case-Laws Income Tax Wed, 21 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450127