https://www.taxtmi.com/caselaws?id=774757 ITAT Delhi held that deemed dividend provisions under section 2(22)(e) were not applicable where sister concerns provided loans to the assessee, as the assessee was neither a beneficial nor registered shareholder in the lending companies. The tribunal noted that while a holding company had substantial interest in all entities, the direct lending relationship did not trigger deemed dividend treatment. Additionally, the tribunal deleted an addition under section 68 for unsecured loans from Global Distributors Limited, finding that identity, creditworthiness, and genuineness were established through arbitration awards and documentary evidence. The assessee succeeded on both issues. en-us Wed, 09 Jul 2025 00:00:00 +0530 Mon, 14 Jul 2025 08:36:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774757 ITAT Delhi held that deemed dividend provisions under section 2(22)(e) were not applicable where sister concerns provided loans to the assessee, as the assessee was neither a beneficial nor registered shareholder in the lending companies. The tribunal noted that while a holding company had substantial interest in all entities, the direct lending relationship did not trigger deemed dividend treatment. Additionally, the tribunal deleted an addition under section 68 for unsecured loans from Global Distributors Limited, finding that identity, creditworthiness, and genuineness were established through arbitration awards and documentary evidence. The assessee succeeded on both issues. Case-Laws Income Tax Wed, 09 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774757