Loan Between Subsidiaries u/s 2(22)(e) Not Deemed Dividend Due to Lack of Shareholder Status.

Deemed dividend addition u/s 2(22)(e) - loan transaction from one subsidiary to another subsidiary company with common parent company - It is not possible to accept the contention that the respondent-assessee should be treated as a shareholder or beneficial owner of the shares in the other subsidiary company. .....

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