In Gopal And Sons (HUF) Vs. CIT, the Hon'ble Supreme Court decided that once the payment is received by the HUF and shareholder is a member of the said HUF and he has substantial interest in the HUF, the payment made to the HUF shall constitute deemed dividend within the meaning of clause (e) of Section 2(22) of of the Income Tax Act, 1961.
Article referred: http://www.lawkam.org/caselaw/shareholder-gopal-cit-kolkata-india/12266/
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