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2018 (6) TMI 1123 - HC - Income TaxTreating the loan received as deemed dividend under Section 2(22)(e) - reopening of assessment - Held that:- If the assessee had made such transfers and registered it with the Company as stipulated under the Companies Act, 1956, specifically Sections 108 to 112 dealing with transfer of shares and debentures, necessarily the transfer would have been registered by the Company and share certificates issued in the name of the transferee. If that was done, it would find reflection in the annual returns filed by the Company. The annual returns, however, shows the assessee holding 328 shares. Obviously, the documents produced by the assessee were cooked up and the revision of returns said to have been filed before the Registrar of Companies, was subsequent to the notice issued under Section 147; an afterthought to wriggle out of the liability. All the authorities having concurred on facts, we do not find any reason to interfere with the orders. No question of law arises from the orders of the Tribunal and we reject the appeals
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