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    <title>2018 (9) TMI 798 - DELHI HIGH COURT</title>
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    <description>Amounts advanced by NBFC lenders were not taxable as deemed dividend under Section 2(22)(e) because the substantial-business exception applied on the lenders&#039; real non-banking financial activities, and the test was not confined to a rigid RBI classification or single percentage benchmark. Employees&#039; provident fund and ESI contributions were deductible only to the extent deposited within the prescribed grace period; delayed payments were disallowed under the governing provisions. Salary expenditure was revenue in nature, and interest on borrowed funds used for infrastructure creation was allowable for the assessment year in question, so the related disallowance was unsustainable.</description>
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