https://www.taxtmi.com/highlights?id=93386 ITAT held that the payments in question do not constitute deemed dividend under section 2(22)(e) because the recipient was not a registered shareholder of the assessee-company; consequently, tax deduction at source under section 194 could not be fastened, and consequential liability under sections 201(1) and 201(1A) does not arise. Characterising the transaction as commercial lending, the Tribunal concluded that neither the deemed dividend provisions nor tax-deduction liabilities apply. The assessee's appeal was allowed and the demand under the said provisions was set aside. en-us Thu, 16 Oct 2025 08:30:14 +0530 Thu, 16 Oct 2025 08:30:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=93386 ITAT held that the payments in question do not constitute deemed dividend under section 2(22)(e) because the recipient was not a registered shareholder of the assessee-company; consequently, tax deduction at source under section 194 could not be fastened, and consequential liability under sections 201(1) and 201(1A) does not arise. Characterising the transaction as commercial lending, the Tribunal concluded that neither the deemed dividend provisions nor tax-deduction liabilities apply. The assessee's appeal was allowed and the demand under the said provisions was set aside. Highlights Income Tax Thu, 16 Oct 2025 08:30:14 +0530 https://www.taxtmi.com/highlights?id=93386