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 holde

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