Assessee and BAPL's dealings are current accounts, not loans; Section 2(22)(e) on deemed dividends doesn't apply.

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....Deemed dividend u/s Sec.2(22)(e) - The loan account is different from a current account with a shareholder and the transactions between the Assessee and BAPL are in the nature of current account and provisions of Sec.2(22)(e ) of the Act will not be applicable - AT....