Section2(22)e
This query is : Resolved
Querist : Anonymous
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?
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
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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