Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also fails.

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....Mutual current-account transactions involving repeated advances, repayments and payments made on another concern's behalf are commercial dealings rather than loans or advances for deemed-dividend purposes. Ledger evidence showing that receipts merely repaid earlier advances supports exclusion from the deemed-dividend provision. Likewise, an alleged unsecured loan cannot be treated as unexplained cash credit where records establish interest-bearing commercial entries and no fresh loan arose in the relevant year. On these findings, deletions of both additions were sustained and the Revenue's appeal was dismissed.....