Section 2(22)(e) Deemed Inapplicable: Loan Not Taxed as Deemed Dividend Due to Property Ownership and Borrowed Funds.

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....Addition u/s 2(22)(e) - deemed dividend - interest bearing Loans - proportionate ownership of property acquired out of borrowed fund by the “company” to the extent of loan/advance lies with the assessee - CIT(A) is justified in holding that the AO is not right in bring to tax sum as a deemed dividend in the hands of the assessee. Since, We held that the provision of section 2(22)(e) of the Act have no application to the facts of the case - AT....