It was held by the Tribunal that since the assessee was not a shareholder of the payer group companies who had advanced loans or advances to the assessee, the amount received by the assessee could not be treated as deemed dividends in the hands of the assessee. (AY.2007-08)
Rainbow Promoters (P.) Ltd. v. ACIT (2022) 95 ITR 232 (Delhi)(Trib.)
S. 2(22)(e) : Deemed dividend-Loans obtained from group companies-Not shareholder of payer group companies-Loan cannot be treated as deemed dividend.