https://www.taxtmi.com/caselaws?id=794022 Loans advanced to a shareholder were held outside deemed dividend treatment because the lender's money-lending activity formed a substantial part of its business and the advance fell within the ordinary course of that business; the borrower also paid interest, supported by TDS certificates and ledger entries, showing no gratuitous benefit. On those facts, the addition under section 2(22)(e) was unsustainable. The High Court further found that the Tribunal's conclusions were factual and disclosed no substantial question of law under section 260A, so the revenue's challenge failed and the deletion of the addition was left undisturbed. en-us Tue, 09 Jun 2026 00:00:00 +0530 Sat, 27 Jun 2026 08:33:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794022 Loans advanced to a shareholder were held outside deemed dividend treatment because the lender's money-lending activity formed a substantial part of its business and the advance fell within the ordinary course of that business; the borrower also paid interest, supported by TDS certificates and ledger entries, showing no gratuitous benefit. On those facts, the addition under section 2(22)(e) was unsustainable. The High Court further found that the Tribunal's conclusions were factual and disclosed no substantial question of law under section 260A, so the revenue's challenge failed and the deletion of the addition was left undisturbed. Case-Laws Income Tax Tue, 09 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794022