https://www.taxtmi.com/caselaws?id=347128 An intimation under section 143(1) does not amount to a merits-based assessment, so reopening under section 147 is not barred as a mere change of opinion when escapement of income is noticed. The reassessment was therefore valid. On the merits, a purported land-sale advance from a closely held company was held to be unsupported by the surrounding facts: the agreement was unregistered, the transaction was not reflected in the company's books, obligations were not performed, and the amount remained with the assessee for years. The sum was accordingly treated as deemed dividend under section 2(22)(e). en-us Fri, 11 Aug 2017 00:00:00 +0530 Tue, 29 Aug 2017 17:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=347128 An intimation under section 143(1) does not amount to a merits-based assessment, so reopening under section 147 is not barred as a mere change of opinion when escapement of income is noticed. The reassessment was therefore valid. On the merits, a purported land-sale advance from a closely held company was held to be unsupported by the surrounding facts: the agreement was unregistered, the transaction was not reflected in the company's books, obligations were not performed, and the amount remained with the assessee for years. The sum was accordingly treated as deemed dividend under section 2(22)(e). Case-Laws Income Tax Fri, 11 Aug 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=347128