No deemed dividend as assessee wasn't substantial shareholder on date of advance as he had already g

IT : Where Assessing Officer made addition to assessee's income under section 2(22)(e) finding that assessee had taken loan from company in which he was holding 38.8 per cent shares, in view of fact that assessee had already gifted 30 per cent shareholding to his wife and son, impugned addition deserved to be deleted