Section 2(22)(e) not applies to a non-shareholder – HC

Recently Hon’ble Bombay High Court has held in the case of CIT vs. Impact Containers Pvt. Ltd. that Section 2(22)(e) of the Income Tax Act, 1961 does not apply to a non-shareholder. Court follows the laid down in Universal Medicare 324 ITR 263 (Bom) which approves Bhaumik Colour 313 ITR 146 (SB)).

It is then urged that the Division Bench judgment in Universal Medicare does not take into consideration the amendments that have been made to the statute from time to time. It is urged that the amendment speci

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