https://www.taxtmi.com/caselaws?id=38795 A company's payment to an intermediary can fall within deemed dividend rules if, on the facts, the intermediary is only a conduit for the shareholder's borrowing. Section 2(6A)(e) of the Indian Income-tax Act, 1922 covers not only direct loans to a shareholder, but also payments made on behalf of a shareholder or for the shareholder's individual benefit. Here, the shareholder's admissions and the surrounding circumstances showed that funds were borrowed through the intermediary and passed on to him, so the company's advance was treated as made for his individual benefit and was assessable as dividend in his hands. en-us Wed, 06 Oct 1976 00:00:00 +0530 Fri, 09 Apr 2010 11:07:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38795 A company's payment to an intermediary can fall within deemed dividend rules if, on the facts, the intermediary is only a conduit for the shareholder's borrowing. Section 2(6A)(e) of the Indian Income-tax Act, 1922 covers not only direct loans to a shareholder, but also payments made on behalf of a shareholder or for the shareholder's individual benefit. Here, the shareholder's admissions and the surrounding circumstances showed that funds were borrowed through the intermediary and passed on to him, so the company's advance was treated as made for his individual benefit and was assessable as dividend in his hands. Case-Laws Income Tax Wed, 06 Oct 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38795