Payer companies not required to deduct TDS on loans to non-shareholders u/s 2(22)(e) due to impracticality.

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....TDS u/s 194 - Deemed dividend u/s 2(22)(e) - when the loans/advances have been given to a non shareholder, then it is impossible for a payer company to ascertain whether it will attract the provisions of section 2(22)(e) or not - provisions of section 2(22)(e) and 194 do not require the payer assessee company to deduct TDS u/s 194 - AT....