https://www.taxtmi.com/caselaws?id=755865 ITAT Ahmedabad quashed the reassessment beyond four years for deemed dividend under Section 2(22)(e). The tribunal held that AO failed to establish assessee's failure to disclose material facts, which is mandatory for reopening beyond four years. Since ITR forms and tax audit reports did not require deemed dividend disclosure during the relevant year, assessee could not be charged with non-disclosure. The account was treated as current account with multiple transactions, and only closing credit balance was considered deemed dividend. The reassessment was deemed invalid and decided in favor of assessee. en-us Fri, 05 Jul 2024 00:00:00 +0530 Mon, 22 Jul 2024 08:38:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755865 ITAT Ahmedabad quashed the reassessment beyond four years for deemed dividend under Section 2(22)(e). The tribunal held that AO failed to establish assessee's failure to disclose material facts, which is mandatory for reopening beyond four years. Since ITR forms and tax audit reports did not require deemed dividend disclosure during the relevant year, assessee could not be charged with non-disclosure. The account was treated as current account with multiple transactions, and only closing credit balance was considered deemed dividend. The reassessment was deemed invalid and decided in favor of assessee. Case-Laws Income Tax Fri, 05 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755865