https://www.taxtmi.com/caselaws?id=38430 A loan or advance treated as a deemed dividend under section 2(6A)(e) of the Indian Income-tax Act, 1922 is not an actual distribution of profits for section 23A purposes. The deeming fiction in section 2(6A)(e) operates only for taxing the amount in the shareholder's hands and cannot be extended beyond its limited purpose. Because section 23A applies only where profits and gains are in fact distributed as dividends, a deemed dividend does not satisfy that statutory condition. On that basis, such a loan or advance is excluded from the computation of dividend distribution under section 23A, and the issue is stated to favour the revenue. en-us Mon, 15 Dec 1975 00:00:00 +0530 Tue, 06 Apr 2010 11:47:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38430 A loan or advance treated as a deemed dividend under section 2(6A)(e) of the Indian Income-tax Act, 1922 is not an actual distribution of profits for section 23A purposes. The deeming fiction in section 2(6A)(e) operates only for taxing the amount in the shareholder's hands and cannot be extended beyond its limited purpose. Because section 23A applies only where profits and gains are in fact distributed as dividends, a deemed dividend does not satisfy that statutory condition. On that basis, such a loan or advance is excluded from the computation of dividend distribution under section 23A, and the issue is stated to favour the revenue. Case-Laws Income Tax Mon, 15 Dec 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38430