Deemed Dividend Not Applicable: Assessee Firm Not Shareholder in Lender Company Under Income Tax Act Section 2(22)(e.

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....Deemed dividend u/s 2(22)(e) - one of the partners of the assessee firm was holding major share holding - Since the assessee firm was not shareholder in the lender company, viz. M/s Siroya FM Construction Pvt Ltd, the impugned amount of loan cannot be taxed in the hands of the assessee firm as deemed dividend - AT....