Sec. 2(22)(e) of Income-tax Act, 1961— Deemed dividend— When a loan by a company to a shareholder in the manner set out in s. 2(22)(e) is treated as a deemed dividend, it is to be treated as payment out of accumulated profits of the company and any legal fiction will have to be carried to its logical conclusion and if the payment under s. 2(22)(e) is treated as a deemed dividend and is required to be so treated to the extent the company possesses accumulated profits, the logical conclusion is that this payment must be considered as adjusted against the company's accumulated profits to the extent it is treated as deemed dividend while calculating accumulated profits of the company and whenever accumulated profits of the company are required to be determined, such an adjustment will have to be made, thus, all additions/disallowances other than addition under s. 2(22)(e) are liable to be set aside and remitted back to the file of the AO when examined on the touch stone of factual matrix— Rajat Minerals (P) Ltd. vs. Dy. CIT [2020] 203 TTJ 955 (RANCHI)