Held that an advance against agreement to sell the property was a trade advance which was in the nature of commercial transaction. Even though the assessee was a substantial shareholder in the company which had made the advance to the assessee, this was not a fit case to invoke the provisions of section 2(22)(e) of the Act. CBDT Circular No. 19 of 2017, dated June 12, 2017  applied to the case of the assessee. Followed CIT v. Raj Kumar (2009) 318 ITR 462 (Delhi)(HC)  (AY. 2015-16)