Deemed Dividends Can't Offset Actual Dividends for Tax Purposes; Different Rules for Section 2(22)(e) Apply.

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....Set off of deemed dividend against actual dividend paid by certain companies - dividend distribution tax as per section 115-O is in respect of dividend covered u/s 2(22)(a) to (d) and such income is exempt in the hands of shareholders u/s 10(34). However, deemed dividend u/s 2(22)(e) is taxable as no dividend distribution tax is payable on this income - set off not allowed.....