Loans to Shareholders Not Deemed Dividends if Lending is Key Business Activity per Section 2(22)(e)(ii) of Income Tax Act.

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....Deemed dividend u/s 2(22)(e) - if the lending of money constitutes substantial part of business of the company, then the loan given by the company to its share holders cannot be considered to be deemed dividend under the provisions of section 2(22)(e) as the same fall under the exception mentioned in section 2(22)(e)(ii). - AT....