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    <title>Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also fails.</title>
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    <description>Mutual current-account transactions involving repeated advances, repayments and payments made on another concern&#039;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&#039;s appeal was dismissed.</description>
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    <pubDate>Mon, 31 Aug 2026 08:28:49 +0530</pubDate>
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      <title>Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also fails.</title>
      <link>https://www.taxtmi.com/highlights?id=103241</link>
      <description>Mutual current-account transactions involving repeated advances, repayments and payments made on another concern&#039;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&#039;s appeal was dismissed.</description>
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