https://www.taxtmi.com/caselaws?id=794599 Section 2(22)(e) deemed dividend could not be applied to tax a recipient company that was not itself the registered shareholder, so revision under section 263 was unjustified on the unsecured loan issue. On the alleged bogus liability in the name of Darsh Developers Private Limited, the Assessing Officer had made no inquiry and no effective rebuttal was shown before the Tribunal, so the assessment was vulnerable to revision on that limited point. The revisionary order was therefore upheld only in part, with relief to the assessee on the deemed dividend issue and sustenance of revision on the unexamined liability issue. en-us Mon, 22 Jun 2026 00:00:00 +0530 Wed, 08 Jul 2026 09:08:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794599 Section 2(22)(e) deemed dividend could not be applied to tax a recipient company that was not itself the registered shareholder, so revision under section 263 was unjustified on the unsecured loan issue. On the alleged bogus liability in the name of Darsh Developers Private Limited, the Assessing Officer had made no inquiry and no effective rebuttal was shown before the Tribunal, so the assessment was vulnerable to revision on that limited point. The revisionary order was therefore upheld only in part, with relief to the assessee on the deemed dividend issue and sustenance of revision on the unexamined liability issue. Case-Laws Income Tax Mon, 22 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794599