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.