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2022 (6) TMI 474 - AT - Income TaxDisallowance u/s 14A r.w. Rule 8D - CIT(A) restricted the disallowance to the extent of dividend income earned by reducing the expenditure apportioned by the assessee and the balance amount of addition was confirmed - HELD THAT:- CIT(A) has rightly confirmed the disallowance under section 14A of the Act after reducing the expenditure apportioned by the assessee from the exempt income earned. Thus, we find no infirmity in the order passed by the ld. CIT(A) on this issue and accordingly, the ground raised by the Revenue is dismissed. Deemed dividend addition u/s 2(22)(e) - HELD THAT:- As decided in own case [2022 (4) TMI 173 - ITAT CHENNAI] the expression 'shareholder' referred to in section 2(22)(e) of the Act refers to both a registered shareholder and the beneficial shareholder. And further that if a person is a registered shareholder but not a beneficial shareholder, then the provisions of section 2(22)(e) of the Act would not apply and likewise if a person is a beneficial shareholder but a registered shareholder then also the provisions of section 2(22)(e) of the Act would not apply. While in the case at hand the ITAT noted that the assessee was not a shareholder at all and hence the provisions of section 2(22)(e) of the Act would not apply. - Decided against revenue.
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