Section 2(22)(e): Deemed Dividend Rules Exclude Loans to Non-Shareholders & Require Dual Shareholder Status.

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....Deemed dividend u/s 2(22) - Treating loan to a non shareholder as deemed dividend - If a person is a registered shareholder but not the beneficial then the provision of section 2(22) (e) will not apply. Similarly, if a person is a beneficial shareholder but not a registered shareholder then also the first limb of the provisions of section 2(22)(e) will not apply. - AT....