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    <title>2020 (5) TMI 263 - MADRAS HIGH COURT</title>
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    <description>The court dismissed the Revenue&#039;s appeals, affirming that reopening the assessment under Section 147 based on audit objections was unjustified. Additionally, treating the loan amount as deemed dividend under Section 2(22)(e) was deemed unsustainable as it was based on a change of opinion rather than valid reasons to believe income had escaped assessment. The court favored the assessee, answering the substantial question of law in the negative.</description>
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      <description>The court dismissed the Revenue&#039;s appeals, affirming that reopening the assessment under Section 147 based on audit objections was unjustified. Additionally, treating the loan amount as deemed dividend under Section 2(22)(e) was deemed unsustainable as it was based on a change of opinion rather than valid reasons to believe income had escaped assessment. The court favored the assessee, answering the substantial question of law in the negative.</description>
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