Loan from QNEI not taxable as deemed dividend u/s 2(22)(e) since Assessee isn't a shareholder. Common shareholding irrelevant.

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....Deemed dividend u/s.2(22)(e) - loan received by the Assessee from QNEI - the Assessee is not a shareholder of QNEI, the amount received from QNEI will not be taxable in the hands of the Assessee as deemed dividend u/s.2(22)(e) of the Act and common shareholding in two companies would not attract the provisions of Section 2(22)(e) of the Act. - AT....