https://www.taxtmi.com/caselaws?id=796179 Loans or advances received by a public trust from a company in which its managing trustee held substantial shareholding cannot be treated as deemed dividend under Section 2(22)(e) on the stated facts. The provision extends the meaning of dividend but does not treat a non-shareholder recipient as a shareholder, and a public trust is not among the specified concerns in Explanation 3. In the absence of evidence that the trust was a conduit for the trustee's individual benefit, the deeming provision does not apply. Reassessment proceedings based on that premise were therefore invalid. en-us Tue, 21 Jul 2026 00:00:00 +0530 Sat, 01 Aug 2026 08:34:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796179 Loans or advances received by a public trust from a company in which its managing trustee held substantial shareholding cannot be treated as deemed dividend under Section 2(22)(e) on the stated facts. The provision extends the meaning of dividend but does not treat a non-shareholder recipient as a shareholder, and a public trust is not among the specified concerns in Explanation 3. In the absence of evidence that the trust was a conduit for the trustee's individual benefit, the deeming provision does not apply. Reassessment proceedings based on that premise were therefore invalid. Case-Laws Income Tax Tue, 21 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796179