Where the assessee held more than 10% shares only on the first day of the previous year and, after transferring a substantial number of shares, its shareholding fell below 10% and continued below that threshold for the remainder of the year, the loan received from the company could not be assessed as a deemed dividend under section 2(22)(e). The Assessing Officer erred in applying the expression “at any time during the previous year” to determine the shareholder’s eligibility, as Explanation 3(b) applies only to a concern other than a company. Since the assessee’s shareholding at the relevant year-end was below 10%, the provisions of section 2(22)(e) were not attracted, and the addition was directed to be deleted. (AY. 2013-14)