2017 (2) TMI 511

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..... T] if the intention of the Legislature was to tax such loan or advance as deemed dividend at the hands of deeming shareholder, then the legislature would have inserted deeming provision in respect of shareholder as well. The legislature has not done so - It is only the person whose name is entered in the Register of the shareholders of the Company as the holder of the shares who can be said to .....

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..... sed as deemed dividend in the hands of the assessee-firm even when all the ingredients of the said provision are satisfied in the case of assessee and Section 2(22)(e) of the Act brings to tax as deemed dividend certain payments made by a company by way of advance or loan to a shareholder or payment to a concern in which the shareholder is a member or partner and in which he has substantial int .....

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