Deemed dividends u/s 2(22)(e) of the Income Tax Act are taxable only for shareholders with substantial interest.

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....Deemed dividend u/s 2(22)(e) - substantial interest in the said concern - The definition does not alter the legal position that dividend has to be taxed in the hands of the shareholder. As such, the dividend within the meaning of cl. (e) of Sec. 2(22) can only be brought to tax in the hands of the shareholder.....