Debate on Deemed Dividend: Should Tax Calculation Be Based on Peak Loan Amount u/s 2(22)(e)?

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....Deemed dividend under Section 2(22)(e) - addition only qua the peak amount - Whether addition should be restricted to the peak amount of the loans given during the year? - Deeming fiction of dividend under Section 2(22)(e) comes to play regarding each and every sum received by the concerned assessee - AT....