No addition can be made u/s 2(22)(e) when assessee is not a shareholder

Issue before tribunal: Whether addition deemed dividend u/s 2(22)(e) as the Appellant company is neither a registered shareholder nor a beneficial shareholder in M/s. Wire & Wireless Satellite Network Pvt. Ltd., the lending company. Whether provisions of Section 2 (22) (e) do not apply to the Appellant company. Brief facts of the case: The assessee company is engaged in the business of cable TV services. The AO noticed that the assessee has taken a loan of Rs.1,08,71,574/- from M/s Wire & Wireless Satellite Network Pvt. Ltd. The AO found that the shareholdings of assessee and M/s. W...