TMI Blog2008 (4) TMI 232X X X X Extracts X X X X X X X X Extracts X X X X ..... that the re-assessment proceedings as well as the notice issued to the Assessee for reassessment were without any justification. - 600 of 2007 - - - Dated:- 3-4-2008 - MADAN B. LOKUR and V.B. GUPTA JJ. R. D. Jolly, for the appellant. Dr. Rakesh Gupta with Ms. Poonam Ahuja, for the respondent. JUDGMENT 1. The Revenue is aggrieved by an order dated passed by the Income Tax Appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... provisions of section 2(22)(e) were invoked. During the A.Y. 1996-97 also the Assessee company received a loan of Rs.1,96,68,192/- from M/s Mokul Overseas Pvt. Ltd. which had accumulated profits of Rs.2,22,73,533/-. There are common Directors in these companies who are also the shareholders. I have reason to believe that deemed dividend of an amount of Rs.1,96,68,192/- has escaped assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... l that the original assessment was framed under Section 143(3) of the Act. The Assessee was required to file the list of shareholders with the complete address as on 31 st March, 1996, which it did; the Assessee also filed confirmation dated 29 th January, 1998 of M/s Mokul Overseas Pvt. Ltd. certifying its closing balance; the confirmation given by M/s Mokul Overseas Pvt. Ltd. also mentions its ..... X X X X Extracts X X X X X X X X Extracts X X X X
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