https://www.taxtmi.com/caselaws?id=778991 ITAT KOLKATA - AT held that amounts advanced or loaned by a company to a shareholder qualify as deemed dividend under s.2(22)(e) only where the advance is gratuitous and arises by virtue of the recipient's status as a beneficial owner (holding =10% voting power); advances given in return for a benefit or consideration conferred on the company by the shareholder do not attract deemed-dividend treatment. The tribunal followed HC and SC precedents interpreting "by way of advance or loan" restrictively. Appeal filed by the revenue was dismissed. en-us Fri, 17 Jan 2025 00:00:00 +0530 Fri, 26 Sep 2025 08:26:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778991 ITAT KOLKATA - AT held that amounts advanced or loaned by a company to a shareholder qualify as deemed dividend under s.2(22)(e) only where the advance is gratuitous and arises by virtue of the recipient's status as a beneficial owner (holding =10% voting power); advances given in return for a benefit or consideration conferred on the company by the shareholder do not attract deemed-dividend treatment. The tribunal followed HC and SC precedents interpreting "by way of advance or loan" restrictively. Appeal filed by the revenue was dismissed. Case-Laws Income Tax Fri, 17 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778991