Exception where substantial part of business of the company is money lending -
Where the lending of money is a substantial part of the business of the company, "dividend" would not include any advance or loan made in the ordinary course of business to a shareholder or to the concern in which such shareholder has substantial interest.
This will help in my current scrutiny case of Income Tax , where ITO charging me deemed dividend, while my company is a NBFC as its substaintial business is only money lending..