Loan Not Gratuitous, Deemed Dividend u/s 2(22)(e) of Income Tax Act Not Applicable.

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....Addition of deemed dividend u/s 2(22)(e) - the loan obtained being not gratuitous in nature, do not fall within the mischief of Section 2(22)(e) of the Act. We thus opine that the action of the Assessing Officer runs counter to the mandate of Section 2(22)(e) of the Act on this score alone- AT....