Deemed Dividend Taxation: Assessee's Share of Accumulated Profits Calculated u/s 2(22)(e) of Income Tax Act.

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....Deemed dividend u/s 2(22)(e) - an advance or loan to to any concern in which such shareholder is a member or a partner and in which he has substantial interest - the proportionate amount of the ‘accumulated profits’ of the lender company worked out on a pro-rata basis of the 22.11% shareholding of the assessee - Additions confirmed - AT....