I am in the business of manufacturing customized furniture. I am also a Managing Director and hold 65% of the paid up shares in a Private Limited Company. A substantial part of my business is obtained from the Private Limited Company. The Private Limited Company passes advances received from its customers to me so I can execute the job-work. The Assessing Officer holds that such advances received by me from the Private Limited Company is in nature of loan and accordingly is deemed dividend within the meaning of Section 2(22)e of the Income Tax Act, 1961. Is this correct?