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2011 (3) TMI 1328 - DELHI HIGH COURTDeemed dividend - Interest free security deposit - Shares instead of cash - Reopening - Held that:- No doubt, notice was issued after the expiry of six years, since the assessment was reopened on the basis of "directions" given by the Appellate authority i.e. the CIT(A), Rohtak, the limitation period, as prescribed under Section 149 of the Act was not applicable, having regard to the provisions of Section 150(1) of the Act. Facts demonstrated above would clearly reveal that admittedly as on 16th March, 1998 when the transaction of lease was entered into between the assessee and the Company, the share holding of the assessee in the Company was much less than 10% herefore, by no stretch of imagination can qualify as deemed income - Decided in favor of the assessee
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