2016 (12) TMI 684

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....me Tax Appellate Tribunal (ITAT) and urges that the impugned order, inasmuch as it upset and set aside the addition made by the Commissioner of Income Tax (CIT) in exercise of the powers under Section 263 of the Income Tax Act, 1963 (in short the Act) bringing to tax certain amounts as "deemed dividend" under Section 2(22)(e) of the Act, was erroneous. 2. The brief facts of the case are that furt....

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..... It is urged by the Revenue that CIT acted within his jurisdiction in concluding that the AO erroneously did not bring to tax the amount that had to be included under Section 2(22)(e) facially itself, therefore, the CIT's order was justified, consequently, the ITAT should not have interfered with that determination. 4. There is no dispute that the search and seizure proceedings in this case did ....