Sanjay Subhashchand Gupta v. ACIT (2022) 95 ITR 89 (SN) (Mum.) (Trib.)

S. 2(22)(e) : Deemed dividend-Holding shares more than 10 Per Cent-Loans from companies assessable as deemed dividend.

Held that both companies were companies in which public were not substantially interested. The assessee held more than 10 per cent. of the shares in the companies. The companies had credited loans to the assessee. Thus, the basic conditions of section 2(22)(e) of the Act were satisfied. There was no infirmity in the order passed by the Commissioner (Appeals) affirming the addition on account of deemed dividend. (AY.2012-13)