Loan to Assessee Classified as Deemed Dividend u/s 2(22)(e), Limited to KDPML's Accumulated Profits at Loan Date.

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....Deemed Dividend u/s 2(22)(e) - receipt of loan -mount received by the Assessee will have to be considered as deemed dividend but only to the extent of accumulated profits of KDPML as on the date of granting of loan/advance - AT....