https://www.taxtmi.com/caselaws?id=182328 The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decision to delete the addition of Rs. 19,89,95,203/- as deemed dividend u/s 2(22)(e) of the Income-tax Act, 1961. Additionally, the Tribunal ruled that the reopening of the assessment u/s 147 was invalid, as it was based on a change of opinion without any failure on the part of the assessee to disclose material facts. Commercial transactions between companies were deemed not falling under the provisions of section 2(22)(e), and reopening assessments after four years necessitated a finding of failure to disclose material facts, which was lacking in this case. en-us Fri, 03 Dec 2010 00:00:00 +0530 Sat, 07 May 2016 13:13:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=182328 The Tribunal dismissed the Revenue's appeal, upholding the CIT(A)'s decision to delete the addition of Rs. 19,89,95,203/- as deemed dividend u/s 2(22)(e) of the Income-tax Act, 1961. Additionally, the Tribunal ruled that the reopening of the assessment u/s 147 was invalid, as it was based on a change of opinion without any failure on the part of the assessee to disclose material facts. Commercial transactions between companies were deemed not falling under the provisions of section 2(22)(e), and reopening assessments after four years necessitated a finding of failure to disclose material facts, which was lacking in this case. Case-Laws Income Tax Fri, 03 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=182328