Section 2(22)(e): Loans and Advances Not Taxed as Deemed Dividends for Shareholders, Legislative Intent Questioned.

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....Deemed dividend u/s 2(22)(e) – If the intention of the legislature was to tax such loan or advance as deemed dividend at the hands of “deeming shareholder“, then the legislature would have inserted deeming provision in respect of shareholder as well, that has not happened - AT....