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ACIT vs. Bhaumik Colour (ITAT Bombay – Special Bench)

COURT:
CORAM:
SECTION(S):
GENRE:
CATCH WORDS:
COUNSEL:
DATE: (Date of pronouncement)
DATE: December 16, 2008 (Date of publication)
AY:
FILE:
CITATION:

U/s 2 (22) (e), deemed dividend can be assessed only in the hands of a person who is a “shareholder” of the lender company;

The expression “shareholder” in s. 2 (22) (e) refers to both a registered shareholder and beneficial shareholder. If a person is a registered shareholder but not the beneficial shareholder than the provisions of s. 2(22) (e) will not apply. Similarly if a person is a beneficial shareholder but not a registered shareholder then also the provisions of Sec. 2(22) (e) will not apply.

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