Dismissing the appeal of the revenue ; the tribunal held that ,holding shares in lender company without voting rights whereas it merely held non-cumulative preference shares with fixed rate of dividend in borrower company, amount of loan is question could not be added to as deemed dividend ( AY.2006 -07)
ACIT v. K.P. Singh. (2018) 171 ITD 638 (Delhi) (Trib.)
S. 2(22)(e):Deemed dividend-Non -Holding cumulative preference shares with fixed rate of dividend- Advance of loan cannot be assessed as deemed dividend .