https://www.taxtmi.com/caselaws?id=788734 Deemed dividend under section 2(22)(e) was held unsustainable because there was no evidence of any actual advance or loan by the company to the shareholders or directors. The addition had been built on a disallowance of bogus purchases and on assumptions about presumed dividend distribution, but a fiscal charging provision must be construed strictly and its deeming fiction cannot be extended beyond its clear terms. On that basis, the addition was deleted in full and the assessees succeeded while the Revenue's cross appeals failed. en-us Wed, 25 Mar 2026 00:00:00 +0530 Fri, 27 Mar 2026 08:52:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788734 Deemed dividend under section 2(22)(e) was held unsustainable because there was no evidence of any actual advance or loan by the company to the shareholders or directors. The addition had been built on a disallowance of bogus purchases and on assumptions about presumed dividend distribution, but a fiscal charging provision must be construed strictly and its deeming fiction cannot be extended beyond its clear terms. On that basis, the addition was deleted in full and the assessees succeeded while the Revenue's cross appeals failed. Case-Laws Income Tax Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788734