Adjustment entries being not in nature of loan or advances are outside the purview of deemed dividend u/s 2(22)(e)

Brief of the Case Gujarat High Court held In the case of CIT (TDS) vs. Schutz Dishman Bio-Tech Pvt. Ltd. that there are large number of adjustment entries between the corporates. Unlike transactions of loans and advances, in this kind of adjustment entries, the movement of funds is both ways and the same is more in the nature of current account rather than a loan account. Transactions in the nature of loans and advances are usually very few and for a longer duration. Henec these entries are not in nature of loan or advances. In the absence of any loans and advances, the provisions of section 2...