Dismissing the appeal of the revenue the Court held that ; the assessee had not made any payment by way of advance or loan to a shareholder, but on the contrary, had received loans from the two companies. Therefore, if at all, the provisions of section 2(22)(e) were applicable to the companies which had made such payments, provided the assessee had the requisite shareholding. The assessee being the recipient of such amounts, the Tribunal was justified in holding that the provisions of section2(22)(e) could not be invoked. No question of law arose.( AY. 2010-11)