Assessee received loans from companies he had a substantial interest in and owned shares, this amount was treated as deemed dividend by the AO u/s 2(22)(e), the Commissioner partly confirmed the addition. On appeal it was held that the qualifying conditions for treating any payment as dividend in terms of the provisions of section 2(22)(e) of the Act were : (i) the payment was in the nature of loan or advance ; (ii) the payment was made to a shareholder who had not less than 10 per cent. voting power interest in the company ; and (iii) or the payment was made to another company in which such shareholder had substantial interest which had been defined as beneficial and entitled to not less than 20 per cent income of the company. However, as all the concerns and their stability were interrelated the advances made in the present case to tide over short-term deficiencies of fund was in the nature of commercial expediency or advances for business purpose only and not in the nature of loans and advances simply benefiting any substantial or beneficial shareholder. (ITA Nos. 44 to 47/Chd/2014 AY. 2006-07 to 2009-10)