https://www.taxtmi.com/highlights?id=102282 Section 2(22)(e) deems certain loans or advances to be dividends but enlarges only the meaning of dividend, not shareholder status. Its Explanation 3 defines "concern" as a HUF, firm, association of persons, body of individuals or company, and does not include a public Trust. A loan or advance from a private company to a public Trust therefore ordinarily cannot be treated as deemed dividend merely because the managing trustee holds substantial shares in the lender. The position may differ if the Trust is itself a qualifying shareholder or acts as a conduit for the trustee's individual benefit. On the stated facts, the reopening order and notices were quashed. en-us Sat, 01 Aug 2026 08:34:29 +0530 Sat, 01 Aug 2026 08:34:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=102282 Section 2(22)(e) deems certain loans or advances to be dividends but enlarges only the meaning of dividend, not shareholder status. Its Explanation 3 defines "concern" as a HUF, firm, association of persons, body of individuals or company, and does not include a public Trust. A loan or advance from a private company to a public Trust therefore ordinarily cannot be treated as deemed dividend merely because the managing trustee holds substantial shares in the lender. The position may differ if the Trust is itself a qualifying shareholder or acts as a conduit for the trustee's individual benefit. On the stated facts, the reopening order and notices were quashed. Highlights Income Tax Sat, 01 Aug 2026 08:34:29 +0530 https://www.taxtmi.com/highlights?id=102282