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Section 2(22)(e) Deemed Dividends Rule Not Applicable: Transaction Between M/s.MEL and M/s.SREL is Business-Based.

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....Deemed dividend as per Section 2(22)(e) - family arrangements - In the facts of the present case, the transaction between M/s.MEL and M/s.SREL being admittedly a business transaction, as is evident from the evidence on record, Section-2(22)(e) is not applicable.....