Funds Received by Shareholder Not Deemed Dividends as Lending is Key Business Activity u/s 2(22)(e.

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....Deemed dividend u/s 2(22)(e) - assessee hold 11.61% of shares in SDIPL and 22.81% in AIPL - Since lending of money was a substantial part of the business of SDIPL and AIPL, the money given by it by way of advance or loan to the assessee could not be regarded as a dividend, as it has to be excluded from the definition of “dividend” by virtue of clause (ii ) of Section 2(22)....