Held that neither the assessee is a substantial shareholder of ATL nor ATL is a shareholder of the assessee. After relying upon various decisions, the ITAT held that since the assessee is not a shareholder in ATL, which has given loan/advance to assessee, therefore, the assessee does not fall under any of the limbs provided u/s 2(22)(e) of the Act, and the same cannot be invoked in the hands of the assessee but only in the hands of KSWPL. (AY. 2013-14, 2014-15, 2016-17, 2017-18)