In the result, the appeals of the assessee bearing ITA No
Bench: Dr. M. L. Meena & Sh. Anikesh Banerjeei.T.A. No.189/Asr/2018 Assessment Years: 2014-15
3)/ Bangalore, ITA 446/Bang/2010 date of pronouncement dated 20/06/2011. The relevant part from paragraph 7.5 is extracted as below: - “Thus, it is obvious that the fiction created in section 2(22)(e) only refersto pure advances or loans. Any amount paid on account of genuine businesstransaction between the entities falls outside the ambit of section