Legal fiction for deemed dividend should not be extended to broaden concept of shareholders

Pawa International Pvt Ltd Vs ACIT (ITAT Delhi)

The appeal filed by Pawa International Pvt Ltd (the assessee) is against the order dated 13.09.2023 by NFAC, Delhi. The primary contention of the assessee is that the CIT(A) erred in confirming the addition of Rs. 53,80,84,475 on account of deemed dividend under Section 2(22)(e) of the Income Tax Act, 1961. The key argument is that the assessee company is not a shareholder, and therefore, the provisions of Section 2(22)(e) should not apply.

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