Deemed dividend provision on inter company transactions

If company is closely held company (public is not substantially interested) and managing director is a shareholder holding not less than 10% voting power (equity shares) then any loans and advances to such shareholder or concern in which such shareholder holding substantial interest then such loans and advances will be treated as deemed dividend u/s 2(22)e.
Only way to save tax is that prove above transactions
Where money lending is the substantial part of the business and the transaction for loan or advance is made in the ordinary course of action, such payment shall not be taxable as deemed dividend

Thanks sir, but the company is in IT sector, so we can't show its business of money lending and it is also not covered in its MOA and AOA, isn't there any other option please suggest if not can you please suggest taxability ?

good clarification and information