https://www.taxtmi.com/caselaws?id=469847 Section 2(22)(e) deemed dividend was held taxable only in the hands of the registered shareholder, not in the hands of a non-shareholder company that merely received the loan. The Tribunal noted that the deeming fiction enlarges the definition of dividend but does not extend liability to a concern that is not the shareholder, even where a common shareholder has substantial interest in both entities. On that legal position, the Principal Commissioner's view that the assessment was erroneous and prejudicial for want of enquiry was unsustainable, and the revisionary assumption of jurisdiction under section 263 failed. en-us Mon, 09 Feb 2026 00:00:00 +0530 Mon, 06 Jul 2026 20:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469847 Section 2(22)(e) deemed dividend was held taxable only in the hands of the registered shareholder, not in the hands of a non-shareholder company that merely received the loan. The Tribunal noted that the deeming fiction enlarges the definition of dividend but does not extend liability to a concern that is not the shareholder, even where a common shareholder has substantial interest in both entities. On that legal position, the Principal Commissioner's view that the assessment was erroneous and prejudicial for want of enquiry was unsustainable, and the revisionary assumption of jurisdiction under section 263 failed. Case-Laws Income Tax Mon, 09 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469847