Regarding deemed dividend

Hi friends,

                This is S.V.Gupta from blore. There is one question regading Sec.2(22)(e).Whether loan/advance given by subsiadary to holding company comes under deemed dividend as per that sec or not. I want for these two situations:

1. wholly owned subsiadary

2. subsuidary(more than 51% holding)

i expect the result soon. thank u