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3. The assessee company is in the business of Register & Transfer Agent, depository participants and share group. The assessee filed return of income declaring income of Rs.6,04,285/-. During the course of assessment proceeding the assessee was asked to provide copy of accounts related to its concerns. The Assessing Officer observed that M/s. Alankit Technologies Ltd. has loan account with Alankit Assigning Ltd. The assessee company is a majority share holder, registered and beneficial of Alankit Technologies Ltd. It is the assessee's case that the loan was given by a subsidiary company who is in the business of advancing loan, i.e. Alankit Technologies Ltd. The Assessing Officer held that all the conditions laid down in Section 2 (22) (e) of the Act were satisfied in respect of loan from Alankit Technologies Ltd. to the assessee company. The Assessing Officer further observed that the case is not covered by any of the exceptions provided in Clauses (i) to (v) of the said Section. Therefore, a sum of Rs. 33,79,166/- was held as deem dividend in the hands of the assessee company to the extent of accumulated profits of Alankit Technologies Ltd. and is added under the head income from other sources. The assessee went in appeal before the CIT(A).

7. We have perused all the records and heard both the parties. While invoking Section 2(22)(e) there are certain parameters on which the Assessing Officer has to make an addition. The Assessing Officer also has to take cognizance to the exception to the said Section. The Assessing Officer has not done the same. In the present case, the CIT(A) after going through all the records as well as submissions of the assessee, has given a clear finding that in the case of Alankit Technologies Ltd. out of total assets of Rs. 2,85,14,90/- about 70% of assets are deployed in loans and advances. The total profit of Alankit Technologies Ltd. as per profit and loss account is Rs.28,23,306/- whereas the interest income is Rs.6,55,814/-. Thus, the interest income is approximately 23.23%. The interest income has been shown as business income by Alankit Technologies Ltd. The various judgments specifically supports the facts of the assessee's case that Lending is the substantial part of the business of the Alankit Technologies Ltd. Accordingly the assessee's case is covered by the exemption provided in Clause (ii) of Section 2(22)(e). The CIT (A) has given a correct finding and there is no necessity of interfering with the same. In light of the decision in the case of CIT Vs. Parle Plastics Ltd. (Supra) the appeal of the Revenue does not sustain.