Receipt of advance from Co. wasn't deemed dividend as money lending was substantial part of its busi

IT : Where assessee, holding 51 per cent shares in a company, obtained loan from its reserves and surplus, since out of total funds available with said company, more than 75 per cent were deployed in loans and advances, amount received by assessee could not be considered as deemed dividend because of exclusion by item (ii) to section 2(22)(e)