Dismissing the appeal of the revenue the Court held that , the Tribunal had rightly held that no addition could be made by way of deemed dividend to the income of the assessee. Although the assessee held more than 10 per cent. of the shares in the creditor companies, S.  2(22)(e) did not include any advances or loans to a shareholder by the company in the ordinary course of business where lending of money was substantial business of the company. It was not disputed that both the creditor companies had money lending as the substantial part of their business. (AY.2015-16)