Internal Rent Adjustments Not Considered Loan or Advance u/s 2(22) of Income Tax Act; No Deemed Dividend.

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....Deemed dividend addition u/s 2(22) - Loan or Advance - The fact that the rents payable by PIPL to the Assessee were adjusted against the monies refundable by the Assessee to PIPL is a matter of adjustment between the parties. That adjustment cannot be the basis to hold that PIPL has given a “loan or advance” to the Assessee - AT....