https://www.taxtmi.com/caselaws?id=797951 Section 68 addition is unsustainable where ledger records and supporting material show no fresh loan or unexplained credit during the relevant year, and the entry concerns interest on loans obtained in earlier years. Deemed dividend treatment does not extend to reciprocal, interest-bearing commercial dealings conducted through a current account. Repayments of prior advances and payments made on behalf of related entities do not become loans or advances merely because funds move between them. Strict construction of the deeming provision excludes such mutual commercial transactions, supporting deletion of both additions. en-us Fri, 21 Aug 2026 00:00:00 +0530 Mon, 31 Aug 2026 08:28:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797951 Section 68 addition is unsustainable where ledger records and supporting material show no fresh loan or unexplained credit during the relevant year, and the entry concerns interest on loans obtained in earlier years. Deemed dividend treatment does not extend to reciprocal, interest-bearing commercial dealings conducted through a current account. Repayments of prior advances and payments made on behalf of related entities do not become loans or advances merely because funds move between them. Strict construction of the deeming provision excludes such mutual commercial transactions, supporting deletion of both additions. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797951