Case Digest: Deemed Dividends u/s 2(22)(e) of the Income Tax Act

Dividend usually refers to the distribution of profits by a company to its shareholders. However, in view of Section 2(22) of the Income Tax Act, 1961, the dividend shall also include the following: (a) Distribution of accumulated profits to shareholders entailing release of the company's assets; (b) Distribution of debentures or deposit certificates to shareholders out of the accumulated profits of the company and issue of bonus shares to preference shareholders out of accumulated profits; (c) Distribution made to shareholders of the company on its liquidation out of accumulated profits; (d) Distribution to shareholders out of accumulated profits on the reduction of capital by the company; and (e) Loan or advance made by a closely held company to its shareholder out of accumulated profits. According to Section 2(22)(e) of the Income Tax Act, deemed dividends refer to loans or advances made by a company (excluding closely held companies) to the following individuals or entities: A shareholder who is the beneficial owner of shares, and has at least 10% of the voting rights. It is important to note that the shares held by the shareholder should not be entitled to a fixed rate of dividend.Any entity in which the shareholder of the company is a member or partner with a significant interest.Any loan or advance made on behalf of, or for the individual benefit of, the aforementioned shareholder, to the extent specified by the law. The judicial interpretations given to ‘deemed dividends’ shed some light on the taxability of the same. Here are all such judicial interpretations and case laws reported at taxscan.in. Advance given to Protect Business Interest of Assessee-Company does not Attract Provisions of Deemed Dividend u/s 2(22)(e): ITAT The Delhi bench of the Income Tax Appellate Authority (ITAT) recently held that the advance given to protect business interest of assessee–company does not attract provisions of deemed dividend under section 2(22)(e) Income Tax Act 1961. Profit Sharing as per MoU cannot be treated as “Deemed Dividend”: ITAT The Delhi Bench of Income Tax Appellate Tribunal (ITAT) in a recent ruling,has held that the profit as per MoU could not be treated as “deemed dividend.” Deemed Dividend Taxable in the hands of Individual Director, Not Firm: Orissa HC A division bench of the Orissa High Court has held that the deemed dividend is taxable in the hands of the individual director only and not from the Firm under section 2(22)(e) of the Income Tax Act, 1961. ‘Security Premium Reserve’ cannot be Included in ‘Accumulated Profit’ for Computing Deemed Dividend: ITAT The Delhi Bench of the Income Tax Appellate Tribunal (ITAT), presided over by a Judicial Member Chandra Mohan Garg and and an Accountant Member Pradeep Kumar Khedla upheld the decision of the Commissioner of Income Tax (Appeal) that the security premium reserve cannot be regarded as part of accumulated profits while deciding the case of Bhagwati Coal Movers (P) Ltd. Addition made for Premium on Redemption of Preference Shares as Deemed Dividend not sustainable: ITAT The Income Tax Appellate Tribunal (ITAT), Bangalore Bench held that addition made for premium on redemption of preference shares as deemed dividend not sustainable. Advancement of Loan in Ordinary Course of Business, Provisions of Deemed Dividend not applicable: ITAT upholds Order of CIT(A) Provisions of the Deemed dividend not applicable on the advancement of the loan in the ordinary course of business, the Pune Bench of the Income Tax Appellate Tribunal (ITAT) upheld the order of the CIT(A). Gratuitous Loan by Company to Shareholders in Return to an advantage cannot be treated as Deemed Dividend: ITAT deletes Addition u/s 2(22)(e) The Delhi Bench of Income Tax Appellate Tribunal (ITAT) presided by Mr. Anil Chaturvedi, Accountant Member, and Ms. Astha Chandra, Judicial Member has held that gratuitous loan by the company to shareholders in return to an advantage cannot be treated as a deemed dividend and deletes addition under Section 2(22)(e) of the Income Tax Act. Transfer of Amount for Business purposes to avoid Forfeiture is not Loans and Advances: ITAT deletes Addition for ‘Deemed Dividend’ Income Tax Appellate Tribunal (ITAT), New Delhi deleted addition for deemed dividend on the ground that the transfer of amount for business purposes was made to avoid forfeiture and held that such a transfer is not loans and advances. Deemed Dividend u/s 2(22)(e) applicable only to Persons who are recipient of Loan and Shareholder of the Payer Company: ITAT The Income Tax Appellate Tribunal (ITAT), Chennai bench has held that the deemed dividend under section 2(22)(e) applies only to persons who are recipients of loan and shareholders of the Payer Company. ITAT deletes Addition of ‘Deemed Dividend’ in the Absence of Proof to establish Payment to Shareholder of Company The Income Tax Appellate Tribunal ( ITAT ) Chennai Bench deleted the addition of “Deemed Dividend” in the absence of proof to establish payment to a shareholder or person who has a beneficiary interest in the company. Deemed Dividend u/s 2(22)(e) not applicable on Non-Shareholders: ITAT While upholding the deletion of addition made on the deemed dividend by the CIT(A) Delhi bench of Income Tax Appellate Tribunal held that deemed dividend u/s 2(22)(e) of Income Tax Act, 1961 is not applicable on the non-shareholder company. Amount advanced for Business Transactions cannot treated as Deemed Dividend: ITAT The Income Tax Appellate Tribunal (ITAT), Chennai held that the amount advanced for business transactions cannot be treated as Deemed Dividend. Interest Free Loans cannot be treated as Deemed Dividends u/s 2(22)(e): ITAT The Income Tax Appellate Tribunal (ITAT), New Delhi comprising Shri Saktijit Dey, JM and DR. B.R.R. Kumar, AM has held that the interest-free loans cannot be treated as deemed dividends under Section 2(22)(e) and upholds the order of CIT(A). Provisions of Deemed Dividend does not attract If Loans & Advances in Normal Business benefits both Payer and Payee: ITAT Income Tax Appellate Tribunal (ITAT), Rajkot bench consisting of Waseem Ahmed, Accountant Member and T. R. Senthil Kumar, Judicial Member held that loans and advances given in normal course of business and if transaction in question benefits both payer and payee companies, provisions of ‘deemed dividend’ cannot be invoked. Provisions of ‘Deemed Dividend’ would attract all the Profits up to the date of Payment Irrespective of AY: ITAT The Mumbai Bench of Income Tax Appellate Tribunal has held that provisions of ‘Deemed Dividend’ would attract all the profits up to the date of payment irrespective of assessment year. Provisions of ‘Deemed Dividend’ would not attract Loans and Advances out of Commercial Consideration and Business Expediency: ITAT The Income Tax Appellate Tribunal (ITAT), Mumbai bench has held that the provisions of deemed dividend under section 2(22)(e) of the Income Tax Act, 1961 would not be applicable to loans and advances out of commercial consideration and business expediency. No TDS deductible as Inter-Corporate Deposit not a Deemed Dividend: ITAT The Ahmedabad Bench of Income Tax Appellate Tribunal (ITAT) has held that no TDS deductible as Inter-Corporate deposit is not a deemed dividend. Amount given for Purchasing Shareholding cannot be treated as ‘Deemed Dividend’: ITAT The Income Tax Appellate Tribunal (ITAT), Delhi bench has held that the amount given for the purchase of shareholding cannot be treated as a deemed dividend for the purpose of section 2(22)(e) of the Income Tax Act, 1961. No question of Treating Amount withdrawn by Assessee as Partner in nature of Loan: ITAT deletes Addition on account of Deemed Dividend The Delhi Bench of Income Tax Appellate Tribunal (ITAT) has deleted addition on account of deemed dividend as no question of treating amount withdrawn by assessee as partner in nature of loan. Loan on Interest from Sister Concern to fulfill the enhanced requirement of Working Capital for Export orders does not amount to ‘Deemed Dividend’: ITAT The Delhi bench of the Income Tax Appellate Tribunal (ITAT), Delhi bench has held that loan on interest received from the sister concern to fulfill the enhanced requirement of working capital for export orders does not attract the provisions of deemed dividend under section 2(22)(e) of the Income Tax Act, 1961. Inter-Corporate Deposits are Advance / Loans, attracts Deemed Dividend Provisions: ITAT The New Delhi bench of the Income Tax Appellate Tribunal (ITAT) has held that the inter-corporate deposits, being in the nature of deposits/loans, shall attract the provisions of deemed dividend under section 2(22)(e) of the Income Tax Act, 1961. No Deemed Dividend without doubting Purpose and Genuineness of Business Transaction: ITAT The Delhi Bench of Income Tax Appellate Tribunal (ITAT) while deleting the addition ruled that the business transaction can not be treated as deemed dividend. Provisions relating to ‘Deemed Dividend’ can’t be invoked since Advances were given to Shareholders for Business Purpose: ITAT The Ahmedabad bench of the Income Tax Appellate Tribunal (ITAT) has held that the income tax department cannot invoke the provisions relating to “deemed dividend” under Section 2(22)(e) of the Income Tax Act, 1961 if the advances were given to the shareholder for the purpose of business and not for their individual benefits. ITAT deletes Addition on account of Deemed Dividend The Income Tax Appellate Tribunal ( ITAT ), Mumbai Bench deleted the addition on account of deemed dividend under section 2(22)(e) of the Income Tax Act, 1961. Madras HC affirms Deemed Dividend to be assessed in the hands of the Shareholder and not in the hands of the Firm The Madras High Court while upholding the order passed by the Tribunal held that the deemed dividend under Section 2(22) (e) is to be assessed in the hands of the shareholder and not in the hands of the firm. Transactions through Current Accounts for Business purposes isn’t ‘Deemed Dividend’: ITAT The Income Tax Appellate Tribunal (ITAT), Delhi Bench ruled that the transactions carried out through current account for business purposes would not fall within the definition of “Deemed Dividend”. So the Section 2(22)(e) of the Income Tax Act, 1961, would not apply. ‘Deemed Dividend’ provisions won’t attract for Reimbursement of Business Expenses of Company: ITAT The Mumbai bench of the Income Tax Appellate Tribunal (ITAT) has recently held that the provisions of deemed dividend under Section 2(22)(e) of the Income Tax Act, 1961 would not attract in case of reimbursement of business expenditure. Normal Business Advances which are not in the nature of ‘Loan’ is not Deemed Dividend: ITAT The Income Tax Appellate Tribunal (ITAT) of Delhi bench held that the transaction where received in advance in the normal course of business and which is not taken as a loan cannot be considered as Deemed Dividend. No Deemed Dividend If Assessee was not a Shareholder at the Time of Advance: ITAT The Pune bench of the Income Tax Appellate Tribunal (ITAT) has held that deemed dividend cannot be applied when the assessee was not a shareholder at the time of the advance Firm, not a Shareholder in Pvt Company can’t be Taxed for Deemed Dividend: ITAT The Income Tax Appellate Tribunal (ITAT), Kolkata bench has held that a Firm, which is not a shareholder in a private company, cannot be taxed for deemed dividend under Section 2(22)(e) of Income Tax Act, 1961. Rent paid as Ordinary Business Transaction can’t be treated as Deemed Dividend: ITAT The Delhi bench of the Income Tax Appellate Tribunal (ITAT), Delhi bench has held that the payment of rent as an ordinary business transaction cannot be treated as deemed dividend under the provisions of section 2(22)(e) of the Income Tax Act, 1961. Deemed Dividend can’t be attributed as Assessee have Regular Business Connection with Company and Transactions constitute ‘Trade Advances’: ITAT The Income Tax Appellate Tribunal (ITAT), Hyderabad bench has held that the provisions of deemed dividend cannot be applied when the assessee has a regular business connection with the Company and the transactions would amount to trade advances. Inter Banking Accounts Transactions between Group Companies can’t be treated as ‘Deemed Dividend ’: ITAT The Mumbai bench of Income Tax Appellate Tribunal (ITAT) decided that since the transaction carried between two group companies were carried as inter-banking accounts transaction then the amount cannot be treated as deemed dividend. Provisions of Deemed Dividend Applicable only to Extent of Accumulated Profits available at the beginning of the relevant FY: ITAT The Hyderabad bench of the Income Tax Appellate Tribunal ( ITAT ) has held that the provisions relating to deemed dividend under section 2(22)(e) of the Income Tax Act is applicable only to the extent of accumulated profits of the company available at the beginning of the relevant financial year. Deemed Dividend can’t be assessable in the hands of Director when AO accepted Company’s Return without any Objection: ITAT The Income Tax Appellate Tribunal ( ITAT ), Delhi bench held that the director cannot be assessed for the deemed dividend when the Assessing Officer had accepted the Company’s return without any objection. Deemed Dividend Provisions not applicable to Current Account Transactions: ITAT In Rajesh Pagaria vs. ITO., the Kolkata Bench of the Income Tax Appellate Tribunal (ITAT) held that the provisions of deemed dividend under Section 2(22)(e) of the Income Tax Act, 1961 doesn’t apply to Current Account transactions. Current Account Transactions would not attract Deemed Dividend: ITAT The Kolkata bench of Income Tax Appellate Tribunal ( ITAT ) has ruled that Current Account Transactions would not attract deemed dividend. Deemed Dividend is different from ‘Dividends’: Kerala HC denies Exemption as No Additional Income Tax was paid A division bench of the Kerala High Court in T.J. Jaikish vs. The Commissioner of Income Tax held that Deemed Dividend is different from ‘dividends’ under section 115(O) of the Income Tax Act, 1961. Provisions of Deemed Dividend not applicable to Current Account Transactions: ITAT A division bench of the ITAT Kolkata comprising N.V.Vasudevan, Judicial Member and Waseem Ahmed, Accountant Member were ruled that the provisions of deemed dividend under section 2(22)(e) of the Income Tax Act would not be applicable to Current Account Transactions. Provisions of Deemed Dividend applicable when Assessee diverted Advance amount received for procuring Import Licenses for Purchase of Shares: Delhi HC While hearing the case of Commissioner of Income Tax vs M/s Prasidh Leasing Limited, the Delhi High Court ruled that Provisions of Deemed Dividend applicable when Assessee diverted Advance amount received for procuring import licenses for purchase of shares under Section 2(22)(e) of the Income Tax Act 1961. Provisions of Deemed Dividend applicable only to extent of ‘Accumulated Profits’ and not to Capital Subsidy/Grant: ITAT In Vinod Kumar Mittal v. Income Tax Officer (ITO), the Jaipur bench of the Income Tax Appellate Tribunal (ITA) recently held that the provisions of deemed dividend under section 2(22)(e) of the Income Tax Act is applicable only to the extent of accumulated profits and not to a capital subsidy or grant. ITAT reiterates that Deemed Dividend is assessable from Partners, Not from Firm since they are the Beneficial Shareholders of the Lender Co. The Cochin bench of ITAT in the case of M/s.Kerala Transport Co. Vs. The Asst.Commissioner of Income-tax recently ruled that deemed dividend is assessable from Partners, not from the Firm since they are the beneficial shareholders of the lender company. No Deemed Dividend If Assessee is not a Shareholder in Payer Company: ITAT The New Delhi bench of ITAT in the case of Mr. Tushar Kothari vs. DCIT held that the provisions of deemed dividend would not attract if the assessee was not a shareholder in the payer company. Supreme Court refers Ankitech Ruling on ‘Deemed Dividend’ to Larger bench The Supreme Court of India has referred C.I.T. vs. Ankitech Private Limited case to larger bench for reconsideration. The Apex Court was considering the question whether Section 2(22)(e) of the Act gets attracted inasmuch as a loan has been made to a shareholder, who after the amendment, is a person who is the beneficial owner of shares holding not less than 10% of the voting power in the Company, and whether the loan is made to any concern in which such shareholder is a partner and in which he has a substantial interest, which is defined as being an interest of 20% or more of the share of the profits of the firm. Amount received by Malayala Manorama from its Subsidiary Co.was part of Regular Business Transactions, Not Deemed Dividend: Kerala HC In the case of The Commissioner of Income Tax and M/s Malayala Manorama Co. Ltd, Kerala High Court recently held that amount received from its subsidiary company cannot be treated as deemed dividend for the purpose of section 2(22)(e) of the Income Tax as the same was part of regular business transaction. Loan from Closely held Company to pay Salary is ‘Commercial Transaction’ for the purpose of ‘Deemed Dividend’: ITAT The Hyderabad bench of ITAT recently declared that any loan taken from the closely held company to discharge the payment of salary is ‘commercial transaction’ for the purpose of ‘Deemed Dividend’ under Section 2(22)(e) of the Income Tax Act, 1961. Amount given as Security for Purchase of Flat cannot be treated as ‘Deemed Dividend’: ITAT In the case of DCIT vs. Smt. Sriram Satyavathi, Visakhapatnam bench of Income Tax Appellate Tribunal (ITA) recently held that an amount given as security for purchase of flat cannot be treated as ‘deemed dividend’ for the purpose of Section 2(22)(e) of the Income Tax Act, 1961. Mere Issuance of a Cheque that was Subsequently Canceled and Returned would not constitute ‘Payment of Sum’ attracting ‘Deemed Dividend’: Allahabad HC A division bench of the Allahabad High Court recently ruled that the provisions of deemed dividend would not attract in case of mere issuance of a cheque that was subsequently canceled and returned. While quashing a departmental appeal against the order of ITAT, the bench clarified that payment of any sum is necessary to constitute ‘deemed dividend’ for the purpose of Section 2(22)(e) of the Income Tax Act, 1961. Advance given by a Company to Its Director for Sale of Land is not Deemed Dividend: ITAT Delhi bench of Income Tax Appellate Tribunal (ITAT) has recently held that advance given by a company to its Director/ substantial shareholder cannot be considered as deemed dividend for the purpose of section 2(22)(e) of the Income Tax Act. No Addition for ‘Deemed Dividend’ when Assessee Pledged his Personal Properties to Bank to Borrow Money for Company: ITAT The Income Tax Appellate Tribunal recently ordered that the provisions of ‘deemed dividend’ under the Income Tax Act would not attract in a case where the assessee pledged his personal properties to the Bank for the purpose of loan and other credit facilities granted to the company. Loan to Directors for Purchase of Land is not ‘Deemed Dividend’ since the Land was Transferred to the Company: ITAT The Income Tax Appellate Tribunal, Visakhapatnam, recently ruled that advances given to the directors of a Company for purchase of land cannot be treated as ‘deemed dividend’ under section 2(22)(e) of the Income Tax Act, 1961 since the land is transferred to the company within time. Provisions of ‘Deemed Dividend’ does not attract in case of Normal Business Transactions: ITAT follows CBDT Circular The Delhi bench of the Income Tax Appellate Tribunal (ITAT) has held that the provisions of Deemed Dividend do not attract in case of normal business transactions. Provisions of ‘Deemed Dividend’ would attract if Loan / Advance was given for Sale of Property: ITAT Bengaluru The Bengaluru Bench of the Income Tax Appellate Tribunal (ITAT), Bengaluru consisting of George George K and Jason P. Boaz has clarified the actions of the revenue in regarding treating of Loans/advances for sale as “deemed dividend” as defined per section 2(22)(e) of the Income Tax Act, 1961. Provisions of Deemed Dividend do not attract If Recipient is not a Shareholder: SC Upholds Delhi HC decision A two-judge bench of the Supreme Court has upheld the order of the Delhi High Court wherein the Court observed that section 2(22)(e) of the Income Tax Act, 1961 would not attract in a case where the recipient is not a shareholder. Deemed Dividend would not attract when the Shareholder, who received the Loan holds 10% of Voting Power of the Company: Gujarat HC While dismissing a departmental appeal, a division bench of the Gujarat High Court held that the provisions relating to ‘deemed dividend’ would not attract when the borrowing by one person and some other person holding not less than 10% of the voting power of the said company. Shareholding by Subsidiary Co. is irrelevant while considering ‘Deemed Dividend’ Liability of Holding Co.: ITAT Kolkata In DCIT v. M/s. The Hooghly Mills Co.Ltd, the ITAT Kolkata held that shareholding by Subsidiary Company is irrelevant while considering ‘deemed dividend’ liability of Holding Company under section 2(22)(e) of the Income Tax Act. Loan from a Company wherein the Partners of the Firm are Shareholders is not ‘Deemed Dividend’, Not Taxable in the hands of Firm: ITAT Delhi In Business Strategy Group v. ACIT, the ITAT, Delhi held that the loan obtained from a Company wherein the partners of the Assessee-Firm are the shareholders cannot be termed as ‘deemed dividend’ of the Firm and therefore, it is not taxable in the hands of the Firm under the provisions of Income Tax Act. Deemed Dividend can only be Assessed in the Hands of Registered Shareholders, Company cannot be assessed: Madras HC In a significant ruling, the division bench of the Madras High Court held that the registered shareholders for whose benefit the money was advanced are assessable on deemed dividend. In the common order, the division bench clarified that the Company cannot be made liable for income tax for the said income. Advance Paid for Subscription of Shares is not ‘Deemed Dividend’: ITAT Hyderabad The ITAT, Hyderabad bench, in DCIT v. M/s. My Home Constructions Private Ltd, held that the provisions of deemed dividend does not attract in a case where the payment received as advance expenditure for subscription of shares. Provisions of Deemed Dividend would not apply if Assessee is neither Share Holder nor Beneficial Share Holder in Company: ITAT Mumbai In a significant ruling, M/s. Om Siddivinayak Creations Pvt Ltd v. ITO, the division bench of the ITAT Mumbai held that the section 2(22)(e) of the Income Tax Act, which deals with the provisions of deemed dividend would not apply if the assessee is neither share holder nor the beneficial shareholder in the company. No TDS on Deemed Dividend to a concern in which Shareholder of Assessee Company is a member as Partner: Rajasthan HC In CIT Jaipur Vs. M/s. Sunny Developers Pvt. Ltd, the division bench of the Rajasthan High Court categorically held that TDS under section 194 of the Income Tax Act is not applicable to payments in the nature of deemed dividend to a concern in which shareholder of assessee company is a member as a partner and the assessee have a substantial interest on such concern. Provisions of Deemed Dividend would not attract when the Credit is result of a Business Transaction, not of Loan or deposit: Madras HC A Division Bench of the Madras High Court, in the case of CIT Chennai v. Mr. C. Subba Reddy, held that the provisions relating to ‘deemed dividend’ does not attract in a case where the credit is the result of a business transaction and not in the nature of a loan or a deposit. Payment Received by an HUF is ‘Deemed Dividend’ if one of its member is Shareholder with Substantial Interest: SC The two judge bench of Supreme Court of India yesterday held that, payments received by Hindu Undivided Family (HUF) is considered as deemed dividend within the meaning of Section 2(22)(e) of the Income Tax Act, 1961 especially in view of the term “concern” as defined in the Section itself. The two-judge bench of the Apex Court had categorically held that provisions of deemed dividend are attracted if HUF gets payment and shareholder is a shareholder in a company with substantial interest. Provisions relating to deemed dividends cannot be invoked in normal business transactions under Income Tax Act: ITAT Delhi The Delhi bench of the Income Tax Appellate Tribunal, in a recent ruling, held that section 2(22)(e) of the Income Tax Act, 1961 is not applicable to pure business transactions. While quashing the order of the assessing authority and the adjudicating authority, the Tribunal observed that the advances made by the assessee company based on an unregistered MOU, cannot be treated as “deemed dividend” for the reason that section 2(22)(e) cannot be invoked in case of normal business transactions. Applicability of DTAA Rate on dividend distribution: ITAT refers the matter to Special Bench The Income Tax Appellate Tribunal (ITAT), Mumbai Bench while doubting Delhi Bench ruling in the case of Giesecke & Devrient Vs ACIT, referred the question of Applicability of Double Taxation Avoidance Agreement (DTAA) Rate to Special Bench subject to the approval of President. Relief to Grasim Industries: ITAT stays Recovery of demands on account of Dividend Distribution Tax, and Interest While providing relief to Grasim Industries, the Income Tax Appellate Tribunal (ITAT), Mumbai Bench stayed the recovery of demands on account of dividend distribution tax, and interest to the tune of Rs 3786.34 crores. Share Purchase as per Order of Company Court constitute Dividend, not Capital Gain: Madras High Court dismisses Cognizant’s Plea The Madras High Court has held that the shares purchased pursuant to the order of Company Court would not amount to capital gain and rather to be treated as a dividend. Dividend Income can’t be disallowed If it was Earned While making Strategic Investment in Subsidiary Company to Control the Interest: ITAT The Kolkata Bench of Income Tax Appellate Tribunal (ITAT) held that if a company earned income while making strategic investment in its subsidiary company to control the interest in the company then the deemed income cannot be disallowed. Tax Credit is Available in respect of Dividend Income received from Oman Co. though the Same is Tax Tree under Omani Law: Delhi HC In Principal CIT v. Krishak Bharati Cooperative Ltd, a Division Bench of the Delhi High Court held that where the assessee society would be entitled to tax credit in respect of deemed dividend tax received from an Omani Company on which it was not liable to pay any tax in Oman by virtue of exemption granted as per the Omani Tax laws. Support our journalism by subscribing to Taxscan premium. Follow us on Telegram for quick updates

Case Digest: Deemed Dividends u/s 2(22)(e) of the Income Tax Act

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