A firm not being shareholder cannot be Taxed for Deemed Dividend

Modern Impex Vs ACIT (ITAT Kolkata) We note that one of the partners of assessee firm Shri Ripple P. Doshi holds 33.20% in the assessee firm. And the firm had received advance/loan from a company called M/s. Modern Solaurum Pvt. Ltd. wherein Shri Ripple P. Doshi was having a shareholding of 25%. So, AO added the accumulated profit of M/s. Modern Solaurum Pvt. Ltd. of Rs.89,930/- as deemed dividend u/s. 2(22)(e) of the Act in the hands of the assessee firm. We note that assessee firm is not a shareholder of M/s. Modern Solaurum Pvt. Ltd. So, sec. 2(22)(e) of the Act is not attracted against the...