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2011 (1) TMI 1160 - HC - Income TaxReopening of the assessment - assessees are directors of the company holding more than 10 per cent share and therefore, in terms of s. 2(22)(e) any amount paid by the company to such directors constitutes deemed dividend and is liable to tax - directors had not filed returns. They filed returns only after the proceedings were initiated under s. 147. Though they disclosed this income in the return – Held that:- assessee is liable to pay tax if the said payment is made out of the accumulated profit of the company, AO was justified in initiating proceedings under s. 147 of the Act for reopening the assessment to bring to tax income that has escaped assessment, decision in favour of the Revenue and against the assessee
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