Assessee did not hold any shares in holding company. Assessing Officer treated loan received by assessee from its holding company as deemed dividend under section 2(22)(e) and added same to its income. Held that since assessee-company was not a shareholder of its holding company, amount received from holding company will not be taxable in hands of assessee as deemed dividend and common shareholding in two companies will not attract provisions of section 2(22)(e) of the Act.  (AY. 2011-12)