https://www.taxtmi.com/highlights?id=99133 Payments made by a sister concern towards software testing and development, and adjusted against the assessee's business bills, were held not to constitute deemed dividend. The Court relied on concurrent factual findings that the transactions arose in the regular course of business, and the Revenue failed to rebut that position. Trade advances and commercial payments that are neither loans nor advances within the meaning of the provision fall outside deemed dividend treatment under section 2(22)(e). The questions of law were answered in favour of the assessee and the Revenue's appeal was dismissed. en-us Fri, 24 Apr 2026 10:17:34 +0530 Fri, 24 Apr 2026 10:17:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=99133 Payments made by a sister concern towards software testing and development, and adjusted against the assessee's business bills, were held not to constitute deemed dividend. The Court relied on concurrent factual findings that the transactions arose in the regular course of business, and the Revenue failed to rebut that position. Trade advances and commercial payments that are neither loans nor advances within the meaning of the provision fall outside deemed dividend treatment under section 2(22)(e). The questions of law were answered in favour of the assessee and the Revenue's appeal was dismissed. Highlights Income Tax Fri, 24 Apr 2026 10:17:34 +0530 https://www.taxtmi.com/highlights?id=99133