Transactions Between MLFS and VSPL Not Deemed Dividends u/s 2(22)(e) for 2016-17; Authorities Erred in Classification.

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....Deemed dividend made u/s 2(22)(e) - The alleged transactions are purely entered between the two concerns in the ordinary course of business as advance or loan for which interest was also paid by MLFS to VSPL for Assessment Year 2016-17. Thus the alleged transaction clearly falls in the exclusion (ii) to section 2(22)(e) of the Act and thus both the lower authorities have erred in treating the alleged sum as deemed dividend in the hands of the assessee for Assessment Years 2015-16 and 2016-17 respectively and therefore addition made is uncalled for. - AT....