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

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Deemed Dividend in excess of accumulated profits u/s 2(22)(e) is taken to be loan itself or should it be taxed u/s 56(2)(x)?
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Dividend under 2(22)(e) does not include amount paid in excess of accumulated profits.

Such excess payment is not covered under 2-22-e.

I think 56(2)(x) is out of context
Going by logic, whenever dividend in excess of accumulated profits is paid u/s 2(22)(a) to (d), it is taxed u/s 56(2)(x).
If we go along the same lines of logic, loan in excess of accumulated profits should be taxed in the hands of the Beneficial owner since if it isn't otherwise taxed, it would be an efficient way to divert funds out of closely held companies.


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