https://www.taxtmi.com/caselaws?id=776912 ITAT held that for a company the "substantial interest" under section 2(22)(e) must be tested at year-end, not at any time during the year. Explanation 3(b) applies to concerns other than companies, so intra-year shareholding reductions do not attract deemed dividend for companies. As the assessee's year-end holding fell below 10%, the loan from the company could not be treated as deemed dividend and the appeal was allowed. en-us Wed, 16 Jul 2025 00:00:00 +0530 Thu, 21 Aug 2025 08:35:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776912 ITAT held that for a company the "substantial interest" under section 2(22)(e) must be tested at year-end, not at any time during the year. Explanation 3(b) applies to concerns other than companies, so intra-year shareholding reductions do not attract deemed dividend for companies. As the assessee's year-end holding fell below 10%, the loan from the company could not be treated as deemed dividend and the appeal was allowed. Case-Laws Income Tax Wed, 16 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776912