2(22)e urgent query

PLease write your query clearly

Suppose X person is as 2 different capacity as individual and his own huf.

now in pvt. ltd. x is as director as individual capacity. now comp. has given loan to capacity as huf.

although person is same but in income tax its 2 different person.

so in case individual or huf 2(22)e would applicable or not.

if x is beneficial shareholder of holding 10% or more in company and he has substantial interest in HUF,then Deemed dividend will be taxed in the hands of HUF.Sec.2(22)(e) is a deeming fiction.Whether representative cap or individual, it doersn't matter