Section 2(22)(e) Deemed Dividends Taxed Only in Shareholders’ Hands: Calcutta HC

PCIT Vs Apeejay Pvt Ltd (Calcutta High Court)

In the case of PCIT vs. Apeejay Pvt Ltd, the Calcutta High Court upheld the decision of the Income Tax Appellate Tribunal (ITAT) regarding the taxation of deemed dividends under Section 2(22)(e) of the Income Tax Act, 1961. The revenue appealed against the ITAT’s ruling that such deemed dividends could only be taxed in the hands of registered or beneficial shareholders. The court dismissed the appeal, aligning with previous decisions of the Supreme Court and other High Courts, which consistently held that Section 2(22)(e) does not

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