section 2(22)(e) or section 271(1)(c)

A loan was takem from a sister concern by the company on a temporary basis and the original return was filed without the provision of section 2(22)(e) being attracted...however a revised returned was filed for that..but the assessing officer has issued the notice u/s 271(1)(c)
kindly suggest the applicability of section 271(1)(c) with the relevant case law