Allowing the appeal of the assessee the Tribunal held that ; Current and inter banking accounts between share holders group companies cannot be considered as loans and advances and addition cannot be made as deemed dividend. Tribunal also held that even otherwise also, the payer companies had already made their investment in capital field more than the accumulated profits and in that situation it cannot be considered that those companies were having physical possession of accumulated profits capable of being disbursed. Therefore, the additions in dispute stand deleted. ( AY. 2008 -09)