Refundable security deposits for property rentals not deemed dividends u/s 2(22)(e) of Income Tax Act. No penalty applied.

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....Deemed dividend u/s 2(22)(e) - refundable security deposits in lieu of letting of the properties - It is a trite law that the deeming fiction has to be strictly construed and such legal fiction cannot be extended for any kind of payment by a company to its shareholder - no penalty - AT....