Tribunal held that the transactions carried out through current account for business purposes would not fall within the definition of deemed dividend. In the instant case the provisions of section 2(22)(e) would not be attracted in the case of the assessee because on most of the occasions the assessee had advanced the amount to the subsidiary and ultimately the balance was squared up at the end of the year. The assessee had also filed a copy of the ledger account of the subsidiary for the preceding A.Y. 2012-13 which revealed that there was a substantial opening balance and the subsidiary company had paid the amount to the assessee and later on the amounts had been returned by the assessee to the subsidiary. A similar pattern of transactions was seen in the earlier year and in the subsequent year as well and no addition had been made by the Department against the assessee in those years on account of deemed dividend under section 2(22)(e). Therefore there was no reason to apply the provisions of section 2(22)(e). The rule of consistency shall have to be followed by the Department. (AY. 2013-14)