Dismissing the appeal of the revenue the Court held that since assessee was not a shareholder in said company from which it received loan, such loan amount could not be treated as deemed dividend. Followed CIT v. T. Abdul Wahid & Co (2020) 428 ITR 456/275 Taxman 101 (Mad.)(HC). (AY. 2013-14)
CIT v. Checkpoint Apparel Labelling Solutions (India) Ltd. (2021) 276 Taxman 312 (Mad.)(HC)
S. 2(22)(e) : Dividend-Deemed dividend-Loan-Not share holder of the Company-Not assessable as deemed dividend.