COMMISSIONER OF INCOME TAX vs MYSODET

The Supreme Court addressed the applicability of Section 104 of the Income Tax Act, 1961, in the context of deemed dividends under Section 2(22)(e). The Court held that a loan to a shareholder, deemed as a dividend, does not constitute a distribution of dividend as required under Section 104 for the purpose of levying additional income tax. Consequently, the Court upheld the Karnataka High Court's decision favoring the assessee, rejecting the Revenue's appeal.