Section 2(22) of the Income-tax Act, 1961—Deemed dividend—For raising an irrebuttable presumption, the first set of facts which are deemed to be conclusive proof of the other, i.e. regarding the advancement of loan to shareholder or to the concern in which such a share holder has substantial interest has to be proved strictly and beyond reasonable doubt and such first limb of the facts cannot be assumed or presumed merely on the basis of suspicion, howsoever strong it may be. - ASSTT. CIT V/s GURDEEP SINGH - [2020] 183 ITD 317 (ITAT-CHANDIGARH)