Deemed dividend does not apply to loans advanced in the ordinary course of a company's substantial money-lending business.

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....Deemed dividend under section 2(22)(e) was held inapplicable where loans from a closely held company were advanced in the ordinary course of its substantial money-lending business. The Tribunal's factual findings, based on the TDS certificate and ledger account, showed that the assessee paid interest on the borrowings and did not receive any gratuitous benefit from the company. Following the assessee's earlier year on identical facts, the Court accepted that money-lending formed a substantial part of the lender's business and that such advances fell outside the deemed dividend provision. As these conclusions were purely factual, no substantial question of law arose and the Revenue's appeal was dismissed.....