Sec. 2(22)(e): Lending-Co. advancing loan only to assessee couldn't claim to be having substantial business of lending
IT: Where lending companies advanced loans only to assessee and not to others, lending companies could not be said to have substantial part of business in money lending and thus loans and advances given to assessee were deemed dividend in light of provisions of section 2(22)(e)
Regards
Prarthana Jalan
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