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2021 (7) TMI 145 - AT - Income TaxReopening of assessment u/s 147 - deemed dividend u/s. 2(22)(e) - HELD THAT:- As gone through the written submissions of the assessee placed before there is no iota of any discussion with regard to challenging of reopening of assessment. The challenging of reopening is also not tenable because the assessing officer had tangible materials before reopening the case which was found during the course of survey operation U/s 133(A). In the opinion of the assessing officer there was a reason to believe that the assessee had escaped its income and, therefore, the legal ground raised by the assessee is dismissed. Deemed dividend u/s 2(22)(e) - We direct the AO to delete the addition made by him u/s. 2(22)(e) on account of loan received by the assessee from M/s. Kiran Infertility Centre Pvt. Ltd. on which consideration in the form of interest was paid by the assessee to the benefit of the Company is not sustainable. Accordingly, ground is allowed.
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