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    <title>2016 (4) TMI 344 - ITAT JAIPUR</title>
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    <description>Amounts advanced in reciprocal real-estate dealings were not treated as deemed dividend under section 2(22)(e) where the company and the shareholder/director were engaged in business transactions, the accounts showed frequent mutual entries with the running balance ultimately squared up, and the advance was supported by an agreement to sell land. On these facts, the payment was characterised as part of a commercial arrangement in the ordinary course of business, not as a loan or gratuitous advance attracting the deeming fiction. The addition under section 2(22)(e) was therefore held unsustainable.</description>
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      <description>Amounts advanced in reciprocal real-estate dealings were not treated as deemed dividend under section 2(22)(e) where the company and the shareholder/director were engaged in business transactions, the accounts showed frequent mutual entries with the running balance ultimately squared up, and the advance was supported by an agreement to sell land. On these facts, the payment was characterised as part of a commercial arrangement in the ordinary course of business, not as a loan or gratuitous advance attracting the deeming fiction. The addition under section 2(22)(e) was therefore held unsustainable.</description>
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