Mere debiting amount by way of journal entry will not attract deemed dividend provisions

INCOME TAX : For invoking provisions of section 2(22)(e), there must be a payment by way of advance or loan, hence, where this vital aspect was missing in case of assessee as neither there was any payment nor company made any advance or loan to assessee, thus debit balance worked out by assessee company will not fall within ambit of provisions of section 2(22)(e) and thus are not applicable in case of assessee

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