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Section 2(22)(e)

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Section 2(24)(Iv) v. 2(22)(E) – Bar On Opening Reassessment

Income Tax : Courts have held that reopening an assessment on identical facts under a different deeming provision is invalid. The key takeaway ...

February 3, 2026 645 Views 0 comment Print

Understanding Deemed Dividend Under Section 2(22) of Income-tax Act, 1961

Income Tax : Learn about deemed dividends under Section 2(22) of the Income-tax Act, 1961, its implications, and key judicial precedents relate...

September 24, 2024 7650 Views 0 comment Print

Conceptual clarity on Deemed dividend

Income Tax : Gain insights on Deemed Dividends under the Income Tax Act: Understand taxability, TDS applicability, and key exemptions for optim...

March 9, 2024 5832 Views 0 comment Print

Deemed Dividend Taxation in India

CA, CS, CMA : Explore intricacies of deemed dividends in India. Understand definitions, applicable transactions, and tax implications. Uncover i...

January 4, 2024 4554 Views 0 comment Print

Taxability of Deemed Dividend under Section 2(22)(e) of Income Tax Act

Income Tax : The dividend income received by non-resident individuals, including Foreign Portfolio Investors (FPIs) and Non-Resident Indian cit...

May 27, 2023 42873 Views 1 comment Print


Latest Judiciary


Section 153C Valid but Addition Fails: No Incriminating Material = No Deemed Dividend

Income Tax : The issue was addition of deemed dividend under search assessment. The tribunal held that without incriminating material, addition...

May 2, 2026 201 Views 0 comment Print

CIT(A) Cannot Enhance on New Issue; JDA Additions & U/s 2(22)(e) Deletions Upheld

Income Tax : ITAT Mumbai held that CIT(A) cannot enhance income by introducing a new issue not examined by the Assessing Officer. The ruling cl...

April 18, 2026 423 Views 0 comment Print

ITAT Ahmedabad: No Penalty for Mere Wrong Claim – U/s 271(1)(c) Deleted

Income Tax : The issue was whether incorrect tax treatment amounts to concealment. The Tribunal held that mere wrong classification in books do...

April 14, 2026 195 Views 0 comment Print

ITAT Kolkata – Section 263 Revision on Deemed Dividend Quashed; Loan Not Taxable in Company’s Hands

Income Tax : The ITAT reaffirmed that Section 2(22)(e) cannot extend the definition of shareholder to a concern receiving the loan. The deemed ...

February 14, 2026 267 Views 0 comment Print

Deemed Dividend U/s 2(22)(e) Largely Deleted & Sec.54 Deduction Allowed

Income Tax : ITAT Delhi held that Section 2(22)(e) cannot apply where the assessee held less than 10% shareholding in the lending company. As s...

February 13, 2026 720 Views 0 comment Print


Latest Notifications


No deemed dividend U/s. 2(22)(e) on trade advances in the nature of commercial transactions: CBDT

Income Tax : Section 2(22) clause (e) of the Income Tax Act, 1961 (the Act) provides that dividend includes any payment by a company, not being...

June 12, 2017 6903 Views 0 comment Print


Deemed Dividend u/s 2(22)(e) cannot be assessed by way of double deeming

August 13, 2024 1347 Views 0 comment Print

ITAT Bangalore rules that deemed dividend u/s 2(22)(e) can’t be assessed by double deeming unless the assessee receives a direct benefit from the company’s payment.

Validity of initiation of reassessment u/s. 147 and 148 must be independently evaluated: Delhi HC

August 10, 2024 1389 Views 0 comment Print

The department issued notice u/s. 148A(b) of the Income Tax Act, 1961, alleging that the petitioner had received loan from its 100% subsidiary i.e., Gul Properties Pvt. Ltd.

Section 2(22)(e) of Income Tax Act is applicable only to registered shareholders

March 27, 2024 2787 Views 0 comment Print

Read about the ITAT Chennai case between DCIT and Gemini Traze RFID Pvt. Ltd. regarding deemed dividend status under Section 2(22)(e) of the Income Tax Act.

Section 2(22) Not Applicable to Non-Beneficiary Shareholders: ITAT Kolkata

March 24, 2024 663 Views 0 comment Print

In DCIT Vs Eko Diagnostic Pvt. Ltd., ITAT Kolkata rules that Section 2(22) of Income Tax Act doesn’t apply to non-beneficiary shareholders in loan-receiving companies.

Deemed dividend u/s 2(22)(e) assessable in hands of beneficial shareholder having substantial interest: ITAT Kolkata

March 19, 2024 1308 Views 0 comment Print

Apeejay Surrendra Management Services Pvt Ltd Vs DCIT (ITAT Kolkata) ITAT Kolkata held that deemed dividend under section 2(22)(e) of the Income Tax Act can be added in the hands of beneficial shareholder who is having controlling interest (substantial interest). Facts- Assessee is engaged in the business of Brand Owning and Consultancy. During the year […]

Business Transactions Shouldn’t be treated as Deemed Dividend: ITAT Delhi

March 18, 2024 762 Views 0 comment Print

In ACIT Vs Adiish Jain, ITAT Delhi ruled on deemed dividend under IT Act, deleting the addition. Detailed analysis of the case & judgment.

Conceptual clarity on Deemed dividend

March 9, 2024 5832 Views 0 comment Print

Gain insights on Deemed Dividends under the Income Tax Act: Understand taxability, TDS applicability, and key exemptions for optimizing your tax planning.

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

January 31, 2024 2499 Views 0 comment Print

Legal fiction created u/s. 2 (22)(e) enlarges definition of dividend only and legal fiction is not to be extended further for broadening concept of share holders.

Delhi HC: Mutual Fund Transactions Treated as Investments, Not Business Activities

January 18, 2024 1221 Views 0 comment Print

A pivotal ruling affirming ITAT’s stance on mutual funds transactions as investments and capital contributions not deemed as dividend under Section 2(22)(e) of the Income-tax Act for AY 2006-07.

Deemed Dividend Taxation in India

January 4, 2024 4554 Views 0 comment Print

Explore intricacies of deemed dividends in India. Understand definitions, applicable transactions, and tax implications. Uncover insights into Section 194 and 2(22) of Income Tax Act.

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