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2018 (2) TMI 1472 - HC - Income TaxDeemed dividend u/s 2(22)(e) - Held that:- The Tribunal has taken a view rightly that a deemed dividend could only have been assessed in the hands of a person who is shareholder of the lender company and not in the hands of the borrowing concern in which such shareholder is a member or partner having substantial interest. Admittedly, in the present case the assessee-company was not a shareholder of the lender company. But, in this case both the lender and the borrower have common shareholders. See CIT v. Ankitech (P) Ltd [2008 (6) TMI 611 - ITAT DELHI] - Decided in favour of assessee.
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