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Deemed Dividend

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(Querist)
04 February 2021 A is Private Limited Co. holding General Reserves. A1 and A2 are the 50% each Registered Share holders.

A1, A2 and B (their mother) holding a free will Property in their name.

A intends to use the Funds from General Reserve and Develop the said Property through Registered Contract.

A1, A2 and B will repay the same to A along with profit once the Development is completed.

Query:
Will it attract Deemend Dividend u/s 2 (22) (e) in the hands of A1 and A2?

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