https://www.taxtmi.com/caselaws?id=411290 Reassessment under sections 147 and 148 was sustained because the recorded reasons showed a belief that income had escaped assessment, the Assessing Officer independently applied his mind, and the approval under section 151 was not shown to be mechanical. The deemed-dividend addition under section 2(22)(e) was also upheld because the assessee held substantial shareholding in both closely related concerns, the amount was booked as an unsecured loan, and the transaction did not escape tax merely by being described as an inter-corporate deposit. Both challenges failed. en-us Wed, 18 Aug 2021 00:00:00 +0530 Sat, 21 Aug 2021 14:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=411290 Reassessment under sections 147 and 148 was sustained because the recorded reasons showed a belief that income had escaped assessment, the Assessing Officer independently applied his mind, and the approval under section 151 was not shown to be mechanical. The deemed-dividend addition under section 2(22)(e) was also upheld because the assessee held substantial shareholding in both closely related concerns, the amount was booked as an unsecured loan, and the transaction did not escape tax merely by being described as an inter-corporate deposit. Both challenges failed. Case-Laws Income Tax Wed, 18 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=411290