Mutual current-account transactions involving repeated advances,...

Mutual current-account transactions involving repeated advances, repayments and payments made on another concern's behalf are commercial dealings rather than loans or advances for deemed-dividend purposes. Ledger evidence showing that receipts merely repaid earlier advances supports exclusion from the deemed-dividend provision. Likewise, an alleged unsecured loan cannot be treated as unexplained cash credit where records establish interest-bearing commercial entries and no fresh loan arose in the relevant year. On these findings, deletions of both additions were sustained and the Revenue's appeal was dismissed.