https://www.taxtmi.com/caselaws?id=59371 Section 2(22)(e) deems certain loans or advances as dividend only when the recipient is a shareholder of the lender company. The provision was construed strictly, and the deemed dividend charge was confined to the shareholder in whose hands the payment is made or for whose benefit it is made; it cannot be assessed in the hands of a non-shareholder concern. The expression "such shareholder" was read to require the same person to be both the registered shareholder and the beneficial owner of the shares. On that construction, a person who satisfies only one of those conditions does not fall within the charge. en-us Wed, 19 Nov 2008 00:00:00 +0530 Thu, 07 Dec 2023 19:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=59371 Section 2(22)(e) deems certain loans or advances as dividend only when the recipient is a shareholder of the lender company. The provision was construed strictly, and the deemed dividend charge was confined to the shareholder in whose hands the payment is made or for whose benefit it is made; it cannot be assessed in the hands of a non-shareholder concern. The expression "such shareholder" was read to require the same person to be both the registered shareholder and the beneficial owner of the shares. On that construction, a person who satisfies only one of those conditions does not fall within the charge. Case-Laws Income Tax Wed, 19 Nov 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=59371