Dismissing the appeal of the revenue the Court held that, the assessee was not a beneficial owner of any shares in the creditor companies which had advanced the loans. No loan had been given by the creditor companies to any concern in which the assessee had a substantial interest. What was contemplated by the second limb of section 2(22)(e) was that the creditor companies gave a loan not directly to its shareholder but to any concern in which such shareholder had substantial interest. The common shareholder having a substantial interest in the assessee as well as in the creditor companies was only SIPL which held 86 per cent. of the shareholding in the assessee and 99 per cent. in the creditor companies. Hence the transaction between the assessee and the creditor companies did not fall within the second limb of section 2(22)(e). ( AY.2009-10 )