35. A review of Article 2, paragraph 22, point e) of the Act would show that three types of payments are included in their folding, which are considered «dividends». Indeed, all three categories are (i) any down payment or loan to a shareholder; (ii) any payment on behalf of a shareholder; and (iii) any payment to the individual benefit of a shareholder. In this case, the notator invoked section 2, paragraph 22, under e), of the act, since the notator is a common shareholder who holds a significant interest in Portescap and An gVR. The consequence is that the notator invoked the second part of section 2(22)e of the Act, namely that the payment of Portescap to GVR was made on behalf of the common shareholder, that is, the notator. The situation is clearly not tenable, given that at the time Portescap`s funds were paid to GVR, the expert did not in fact hold any interest in GVR. Therefore, in the case of H.K. Mittal (supra), the Hon`ble Allahabad High Court decision, in the case of H.K. Mittal (supra), is clearly opposed to revenues, since the reference date for the review of the participation model is the date on which the amount was advanced. With respect to CIT (A), he confirmed the notator`s approach by noting that even before the valuation of becoming a shareholder of GVR, the notator held 100% of The shares of Videojet, which in turn held 100% of GVR`s shares and was therefore an advantageous shareholder of GVR at the time the disputed amounts of Portescap were given to GVR. We believe that the conditions in paragraph 2, paragraph 22, under e) of the law for the treatment of an amount as a «dividend» must be interpreted accurately and, in this context, the approach of the CIT (A) is quite untenable. With the exception of a false allegation, CIT (A) does not justify the manner in which the notator became a useful shareholder of GVR, although it did not have a direct interest on the relevant dates, but merely by holding shares in its subsidiary Videojet. In addition, the CIT (A) invoked the third part of Article 2, paragraph 22, under e), of the Act, which states that a payment to a shareholder is also considered a «dividend» within the meaning of Article 2, paragraph 22, point e) of the Act.
In this regard, we note that neither the valuation order nor the order of CIT (A) contains any material to indicate that portescap`s payment to GVR was for the individual benefit of a Portescap shareholder; in any event, it is not possible to immediately conclude that the payments made to GVR on 29.10.2009, 02.03.2010 and 3.03.2010 were to the individual advantage of the notator, since the notator was not even a shareholder of Portescap on the aforementioned dates. Therefore, it is not warranted that, in the current situation, the CIT (A) invokes the third part of paragraph 2 (22) of the Act. Therefore, to the extent that it is a matter of including 90.00,000 UK of Portescap in the GVR in the scope of Article 2, paragraph 22, letter e), of the law, this is quite untenable. We`ve got this. This document consists of a draft inter-Corporate Deposit/Loan Facility agreement between the lender, borrower and lender to grant and grant the borrower a business-to-business deposit in changeable word format, so it is convenient to use you and save time and effort. Acceptance pays interest on outstanding deposits on a quarterly basis, under the terms below, will be granted by «Holding private limited NBFC» to its «NBFC private limited associates» and, conversely, in accordance with the RBI circular of 01.09.2016, falls under the «Corporate Inter Deposit» under the Public Fund, since no public funds are involved in the public fund.