https://www.taxtmi.com/caselaws?id=27176 Reassessment under section 147(a) was justified because the record prima facie suggested that all primary facts had not been fully and truly disclosed, particularly regarding the nature of the advance, the dissolution deed, and the assessee's capacity in the partnership. The reopening was therefore valid, even though the later merits of the addition could still fail. The amount advanced was not assessable as deemed dividend under section 2(6A)(e) because the deeming provision applies only to an advance made to the registered shareholder in the relevant legal capacity. As the advance was to a third party and not shown to have been made to the assessee individually, it could not be taxed as dividend income in his hands. en-us Thu, 16 Feb 1984 00:00:00 +0530 Thu, 11 Feb 2010 12:41:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=27176 Reassessment under section 147(a) was justified because the record prima facie suggested that all primary facts had not been fully and truly disclosed, particularly regarding the nature of the advance, the dissolution deed, and the assessee's capacity in the partnership. The reopening was therefore valid, even though the later merits of the addition could still fail. The amount advanced was not assessable as deemed dividend under section 2(6A)(e) because the deeming provision applies only to an advance made to the registered shareholder in the relevant legal capacity. As the advance was to a third party and not shown to have been made to the assessee individually, it could not be taxed as dividend income in his hands. Case-Laws Income Tax Thu, 16 Feb 1984 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=27176