If the assessee does not have a substantial interest namely beneficial entitlement of 20% or more of the income in a concern receiving any loan or advance from a company then such a loan or advance cannot be treated as deemed dividend (AY. 2006-2007)
Dy. C. I. T. v. Roshan Lal Jindal (2019) 71 ITR 596 (Chd. )(Trib.)
S. 2(22)(e) : Deemed dividend-Advance given to society-Advance not to be treated as deemed dividend.