https://www.taxtmi.com/caselaws?id=466606 Whether a loan from a fellow subsidiary constitutes a deemed dividend under the Income tax Act turns on the presence of a shareholder nexus; the deeming provision requires that the recipient be a shareholder of the lending company, and absent that nexus the amount cannot be treated as a dividend - outcome: the Rs.100 crore advance is not a deemed dividend. Whether a revision order under the revisional power could recharacterise the loan as a deemed dividend depends on the legal basis for invoking the deeming provision - outcome: the revision under revisionary power is unsustainable and is set aside. en-us Wed, 26 Feb 2025 00:00:00 +0530 Fri, 13 Feb 2026 19:07:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=466606 Whether a loan from a fellow subsidiary constitutes a deemed dividend under the Income tax Act turns on the presence of a shareholder nexus; the deeming provision requires that the recipient be a shareholder of the lending company, and absent that nexus the amount cannot be treated as a dividend - outcome: the Rs.100 crore advance is not a deemed dividend. Whether a revision order under the revisional power could recharacterise the loan as a deemed dividend depends on the legal basis for invoking the deeming provision - outcome: the revision under revisionary power is unsustainable and is set aside. Case-Laws Income Tax Wed, 26 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=466606