https://www.taxtmi.com/caselaws?id=469787 Reopening was sustained because the Assessing Officer recorded an independent belief that the assessee was the beneficial shareholder in both closely held companies and that accumulated profits had escaped assessment as deemed dividend. The loan between the companies was held taxable in the common shareholder's hands under the deemed-dividend rule, and the plea that it was a commercial or money-lending transaction failed for want of supporting material. The addition was confined to accumulated profits, with no further reduction to a peak figure or proportionate shareholding basis. Consequential interest under sections 234A, 234B and 234C was also sustained, and the assessee's appeals were dismissed. en-us Mon, 10 Mar 2025 00:00:00 +0530 Fri, 03 Jul 2026 19:00:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469787 Reopening was sustained because the Assessing Officer recorded an independent belief that the assessee was the beneficial shareholder in both closely held companies and that accumulated profits had escaped assessment as deemed dividend. The loan between the companies was held taxable in the common shareholder's hands under the deemed-dividend rule, and the plea that it was a commercial or money-lending transaction failed for want of supporting material. The addition was confined to accumulated profits, with no further reduction to a peak figure or proportionate shareholding basis. Consequential interest under sections 234A, 234B and 234C was also sustained, and the assessee's appeals were dismissed. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469787