https://www.taxtmi.com/caselaws?id=792066 A loan advanced by a closely held company to its shareholder is treated as deemed dividend under section 2(22)(e) when the statutory conditions are satisfied. Its interest-bearing character or later repayment does not, by itself, take the advance outside the provision. The decision in Pradip Kumar Malhotra was treated as fact-specific and not controlling, while Smt. Tarulata Shyam was applied for the principle that the statutory language admits no equitable exception once the conditions exist. An agreed assessment does not create estoppel in law, but the operative question remains the statutory applicability of section 2(22)(e). en-us Wed, 20 May 2026 00:00:00 +0530 Fri, 22 May 2026 07:06:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792066 A loan advanced by a closely held company to its shareholder is treated as deemed dividend under section 2(22)(e) when the statutory conditions are satisfied. Its interest-bearing character or later repayment does not, by itself, take the advance outside the provision. The decision in Pradip Kumar Malhotra was treated as fact-specific and not controlling, while Smt. Tarulata Shyam was applied for the principle that the statutory language admits no equitable exception once the conditions exist. An agreed assessment does not create estoppel in law, but the operative question remains the statutory applicability of section 2(22)(e). Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792066