Shareholding of one partner and not cumulative holding of all partners should exceed 10% to invoke sec. 2(22)(e)
IT : Where shareholding of each partners of assessee-firm as well as of assessee-firm in closely held company is less than 10 per cent, even though their cumulative shareholding is more than 10 per cent, section 2(22)(e) cannot be resorted to for treating amount advanced by company as deemed dividend
Regards
Prarthana Jalan
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