SECTION 2(22)(e) OF INCOME TAX ACT 1961

Dear Members and friends,

Kindly reply your view on the following situation:-

Mr.A and Mrs.A are share holder of A ltd and B ltd. holding all shares in the same ratio. The A ltd transfer funds to B ltd and B ltd transfer funds to A ltd at different dates other than Business transaction and also business transaction (the A ltd giving business B ltd). Altd having accumulated profits

In the above case, I need to know whether the funds transfer will attract Sec 2(22)(e)- Deemed dividend of the Income tax act, 1961,

Thanks and Regards,

Hari Narayanan, B.com ., Grad C.W.A., CA-PCC.,