Deemed dividend

Dear members

A Private ltd company has share capital of Rs . 1 Lakh and Rs. 2 Cr as share premium under the head reserves and surplus having A & B as shareholders and directors with 50% shareholding. Now this company advances Rs. 2 Cr to a partnership firm( in which both A & B are partners with 50% share). Wil this transaction come under the perview of Deemed Dividend u/s 2 (22)(e).

As per my view since this does not comes under the definition of "Accumulated Profits" the same should be outside the perview of Deemed dividend.

An Expert opinion in this regard shall be highly appreciated

Regards,