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2011 (5) TMI 218 - HC - Income TaxAddition - Deemed dividend u/s 2(22)(e) - Loan - no evidence could be produced regarding the allotment of shares - In this regard also, the observations of the Tribunal are not only unwarranted but devoid of any basis - It seems to have taken as correct what was stated by the assessee before it. We have seen the order of the AO which is well reasoned and a speaking one - these were questions of facts which were recorded by the authorities below, but since great perversity and infirmity was pointed out by the learned counsel for the Revenue in the findings and observations recorded by the Tribunal - Decided against the assessee
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