Held, that the payments were provided due to business exigencies for the sole benefit of the company and not for the individual benefit of a shareholder. The Department was not able to show that any benefit accrued to the assessee out of the loans and advances given by GAPL. The assessee at the end of the fiscal year deducted tax at source on interest as calculated on the entire transaction with GAPL. Therefore, the question of the applicability of the provisions of section 2(22)(e) of the Act did not arise. (AY. 2014-15, 2016-17)