For application of section 2(22)(e) a person should be both registered as well as beneficial shareholder

Issue before court: Whether proceedings u/s 201 can be initiated against assessee on account of default in deducting TDS after the lapse of four years. Whether provisions of section 2(22)(e) can be attracted when shareholder is either registered shareholder or beneficial shareholder. Brief facts: These appeals pertain to years 1999-00, 2000-01 & 2002-02. Ms. Harjit Kour, who is a share holder of M/s Pure Drinks Ltd. borrowed funds from CJ International Hotel Ltd. AO invoked provision of section 2(22)(e) by holding that Harjit Kour had more than 10 % stake in assessee company. AO also fo...