https://www.taxtmi.com/caselaws?id=26109 In reassessment under sections 147 and 148, liability is determined by the substantive law applicable to the relevant previous year, so section 12(1B) of the 1922 Act may still govern if it applied to the charge, and the absence of an identical 1961 provision does not by itself exclude it. On the deemed-dividend issue, a mere accounting entry is insufficient without evidence that the payment was made to the assessee or reached him as a loan or advance; where the record shows payment to a firm and no link to the individual, the statutory charge is not established. A wrong reference to section 2(22)(e) does not cure that factual deficiency. en-us Tue, 10 Jun 1986 00:00:00 +0530 Tue, 02 Feb 2010 18:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=26109 In reassessment under sections 147 and 148, liability is determined by the substantive law applicable to the relevant previous year, so section 12(1B) of the 1922 Act may still govern if it applied to the charge, and the absence of an identical 1961 provision does not by itself exclude it. On the deemed-dividend issue, a mere accounting entry is insufficient without evidence that the payment was made to the assessee or reached him as a loan or advance; where the record shows payment to a firm and no link to the individual, the statutory charge is not established. A wrong reference to section 2(22)(e) does not cure that factual deficiency. Case-Laws Income Tax Tue, 10 Jun 1986 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=26109