Loan/Debt from a company to a firm thereby to the assesse, who has substantial interest in company and firm is not deemed dividend u/s 2(22)(e)

Brief of the case The assesse was managing director of Sahara India Savings and Investment Corporation Ltd. (hereafter “SISICOL”) during assessment year (AY) 1992-93; he was also a partner of M/s. Sahara India (hereafter referred to as “the firm”). In terms of an agreement, the firm was to act as an agent to promote, conduct, introduce and secure business under SISICOL’s schemes. The firm -in tune with its contractual obligations, had to remit Rs. 26,24,12,222/- on 31-03-1992, which it had collected and was payable to SISICOL. Between 01-04-1991, and 31-03-1992, the f...