https://www.taxtmi.com/caselaws?id=445236 The Gujarat HC quashed the reopening of assessment under Section 147 for deemed dividend addition under Section 2(22)(e). The court held that revenue's reasons to believe were based solely on existing scrutiny records, balance sheet, and P&L account without any fresh tangible material. The assessee company was not a shareholder of the lending company, and loans were given in normal course of business benefiting both parties. Following precedents from Delhi HC and SC, the court ruled that reasons must have proper linkage with belief formation, deciding in favor of the assessee. en-us Mon, 25 Sep 2023 00:00:00 +0530 Thu, 02 Nov 2023 17:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=445236 The Gujarat HC quashed the reopening of assessment under Section 147 for deemed dividend addition under Section 2(22)(e). The court held that revenue's reasons to believe were based solely on existing scrutiny records, balance sheet, and P&L account without any fresh tangible material. The assessee company was not a shareholder of the lending company, and loans were given in normal course of business benefiting both parties. Following precedents from Delhi HC and SC, the court ruled that reasons must have proper linkage with belief formation, deciding in favor of the assessee. Case-Laws Income Tax Mon, 25 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=445236