1988 (12) TMI 89 - BOMBAY HIGH COURT

Extract:
.......question is obvious because it is only the payments or advances to the extent of accumulated profits that can be treated as loans or advances within the meaning of section 2(22)(e) and this is what the Tribunal has done. In the above view of the matter, the question is answered in the affirmative and in favour of the assessee. No order as to costs.