Sec. 2(22) of the Income-tax Act, 1961 - Deemed dividend - The assessee was holding more than 10% of the shares in both the companies in question, the provisions of section 2(22)(e) of the Act would come into play. However, the section further provides that the dividend does not include any advances or loan made to a share holder by the Company in the ordinary course of business where lending of money is a substantial part of the business of the Company. It is not in dispute that both the companies were having money lending as the substantial part of their business. Therefore, the Tribunal has rightly hold that no addition can be made by way of deemed dividend in the case of the assessee. Accordingly, the Tax Appeal of the revenue dismissed. - PR. CIT V/s MOHAN BHAGWATPRASAD AGRAWAL - [2020] 270 TAXMAN 126 (GUJ)