Deemed dividend can be made applicable only in the hands of registered shareholders

Issue before Court: Whether provision of section 2 (22) (e) can be invoked when assessee is not a registered share holder. Brief Facts: Assessee filed its return of income declaring income at Rs. 39,04,210/-. The AO Completed assessment at Rs. 8,98,94,480/-. The appellant company received loans of Rs. 23 lakhs and Rs. 4.01 crores from M/s Triangle Builders & Promoters Pvt. Ltd. and M/s Countrywide Promoters Pvt. Ltd. respectively. The appellant reflected these transactions in its balance sheet as loan received during the year. The Assessing Officer was of the opinion that these are covere...