Settled View on section 2(22)(e) of the Income Tax Act. trade advances -reg.

Trade advances not treated as deemed dividend where bona fide commercial transactions-department instructed to stop filing appeals.

Section 2(22)(e) treats certain payments by closely held companies as deemed dividends to the extent of accumulated profits. Judicial decisions have held that bona fide trade advances and commercial transactions-such as advances adjusted against job-work dues, advances for enabling contract performance, or security deposits in the ordinary course of business-do not constitute an 'advance' under section 2(22)(e). Consequently, the tax department will cease filing appeals on this ground and may withdraw or not press existing appeals.