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2 22 (e) of the it act, 1961 - union budget 2018 fy 2018-19

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27 February 2018 Out of the Accumulated profits `A’ Pvt Ltd Co had given (prior to AY 2016-17) interest free advance to `B’ Pvt Ltd Co. ` B’ Pvt. Ltd Co. is neither a beneficiary nor registered shareholder of the `A’ Pvt. Ltd. Co.
`A’ Pvt. Ltd. and `B’ Pvt. Ltd. Co. have got the same directors who hold 50% shares each in both the Companies.
Question: With reference to the above we wish to know whether deemed dividend u/s 2 22 (e) is applicable to the above transaction.
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Bhaskaran Chackrapani Warrier

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Bhaskaran Chackrapani Warrier (Expert)
27 February 2018 Recipient of loan is not a shareholder of lending company,hence 2(22)(e) doesn't
apply.

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