https://www.taxtmi.com/caselaws?id=336039 The HC held that additions under Section 263 regarding deemed dividend under Section 2(22)(e) were erroneous and prejudicial to Revenue's interest, as no new material arose from search and seizure proceedings. Since the amounts were declared in original returns and no wilful concealment was established, addition under Section 153A was unwarranted. The court upheld ITAT's view that search-based additions must rely on seized material, preventing repeated reassessment attempts. The decision was against Revenue. en-us Tue, 22 Nov 2016 00:00:00 +0530 Wed, 23 Jul 2025 12:53:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=336039 The HC held that additions under Section 263 regarding deemed dividend under Section 2(22)(e) were erroneous and prejudicial to Revenue's interest, as no new material arose from search and seizure proceedings. Since the amounts were declared in original returns and no wilful concealment was established, addition under Section 153A was unwarranted. The court upheld ITAT's view that search-based additions must rely on seized material, preventing repeated reassessment attempts. The decision was against Revenue. Case-Laws Income Tax Tue, 22 Nov 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=336039