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Section2(22)e

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Querist : Anonymous

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Querist : Anonymous (Querist)
25 July 2010 One of my client which is a PVT LTD company
gave a loan to a partnership firm. MR X, MR Y EACH hold 9% shares in the company and simultaneously EACH of them have 12% profit share in the firm.

I want to know whether 2(22)e is

1)Applicable in this situation or not?

2)2(22)e is a test to be made on MR X and
MR Y separately?

3)Is it applicable for aggegate shareholdings
also?

25 July 2010 no it is not applicable because no shareholder holds 10% share

25 July 2010 Agree Sec 2(22)(e) is not attracted.
For details also check article through following link----

https://www.caclubindia.com/articles/deemed-dividend-section-2-22-e-of-income-tax-act-1961-6121.asp




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