The assessee was not the shareholder one of the partners in the assessee was a shareholder in the company that advanced the loan to the assessee. Addition cannot be made as deemed dividend. (AY. 2013-14)
Perfecta Lifestyle v. ITO (2021) 90 ITR 689 (Bang.)(Trib.)
S. 2(22)(e) : Deemed dividend-Not shareholder of company which had advanced loan to assessee-Loan cannot be treated as deemed dividend.