Unsecured loan not deemed dividend u/s 2(22)(e) due to lack of registered shareholder status despite common directors.

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....Disallowance u/s. 2(22)(e) - assessee has received unsecured loan and assessee company from whom it has obtained unsecured loan there were two common directors - Since the assessee company was not registered share holder in the company from whom the loan was obtained therefore no addition can be made as deemed dividend in the hands of the assessee company merely because there was a common shareholder in the payee company and the assessee company. - No additions - AT....