The Tribunal held that since assessee has issued redeemable debentures and M/s Jasubhai Business Services (P.) Ltd. has subscribed for the debentures and during this year, they have also exercised the options and assessee has redeemed the debentures and current outstanding amount is of Rs. 2,02,25,000/. This transaction involving issue of securities, even though it is a private placement but it cannot be considered as a loan transaction. The provisions of section 2(22)(e) of the Act are not attracted, it attracts only when loan and advances taken in place of direct issue of dividends. In order to avoid dividend tax, some of the assessee are resorting to taking loan instead of dividend being issued to the respective shareholders. The securities are a separate scripts and having stand alone capital liability, which cannot be equated with loan, which is current liability. As regards the advance for purchase of machinery  it being commercial transaction provision of deemed dividend is not attracted .   As regards  intercorporate  deposit Tribunal held that  merely because the intercorporate was repaid before end of the relevant year it cannot be held that deemed dividend provision is not attracted . ( AY . 2013 -14)