The AO contended that the assessee had obtained substantial unsecured loans from its amalgamated company in which a common director held a substantial interest, and therefore sought to treat the amount as a deemed dividend under section 2(22)(e). The Court, however, noted that the amounts in question did not represent unsecured loans, but arose from credit balances in running accounts, comprising payment receipts, margins, interest on margins, and trade advances. Such trade-related credit balances were held to be outside the scope of section 2(22)(e). Accordingly, the reassessment proceedings were held to be unsustainable and were quashed and set aside. (AY.2016-17)