23 March 2009
I have two Pvt. Co. namely A ltd. & B Ltd. In which our share holding pattern are as bellow:- Equity Share in A Ltd. 25% Equity Share in B Ltd 7%
B ltd given loan to me Rs. 22,00,000/- is it deemed dividend u/s 2(22)(e) of IT Act?
A ltd given loan to B ltd Rs. 2,00,000/- is it deemed dividend u/s 2(22)(e) of IT Act?
24 March 2009
You do not have substantial interest in B, and hence loan from B to you is not a deemed divident within the meaning od 2(22)(e). Whether B hold any share in A or not. In fact this question can be answered only after examining the shareholding structure in detail, if any pyramid structure is there etc. Better consult a professional with all details.
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