Deemed Dividends u/s 2(22)(e): Taxable Only to Verizon Singapore, Not the Borrowing Entity.

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....Deemed dividend u/s 2(22)(e) - taxability in hand of concern - proper reading of Section 2(22)(e) can only lead to one conclusion that the amount which is borrowed by the Assessee from VCIPL, in which Verizon Singapore holds more than 10% of voting power can if it all, be taxed only as deemed dividend in the hands of Verizon Singapore and not the Assessee - no substantial question of law arises....