Deemed Dividend u/s 2(22)(e)


This query is : Resolved 

(Querist)
30 October 2008 Whether loan by a foreign holding company to its Indian subsidiary would attract the provisions of S. 2(22)(e)of the Income Tax Act ?

30 October 2008 definition of company in IT Act includes
a foreign body corporate as well.

Raman R (Expert)
30 October 2008 With reference to inter corporate loan/deposit permitted under the Companies Act, how to prove it to the income tax department that the loan extended to a holding or subsidiary is really a loan or deposit so that it will not attract the provisions of deemed dividend.


Regards,

R. Raman


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