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2020 (10) TMI 1154 - HC - Income TaxDeemed dividend u/s 2 (22) (e) - Whether for attracting the provisions of Section 2(22)(e) a shareholder has not only to be a beneficial shareholder but also a registered share holder? - to be assessed in the hands of the share holder or in the hands of the firm - share holder of the company had substantial interest in the firm - HELD THAT:- Substantial Questions of Law raised by the Revenue in the instant case was considered by this Court earlier in the case of The Commissioner of Income Tax, Chennai Vs. M/s T.Abdul Wahid & Co [2020 (9) TMI 977 - MADRAS HIGH COURT] wherein held records placed before the assessing officer clearly shows the nature of transaction between the firm and the company and it is neither a loan nor an advance, but a deferred liability. These facts have been noted by the assessing officer. Tribunal rightly reversed the order passed by the CIT(A) affirming the order of the assessing officer. - Decided against revenue.
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