Reopening of Assessment u/s 147 Invalid Due to Over Four-Year Gap; Deemed Dividend Not Applicable to Petitioner.

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....Reopening of assessment u/s 147 - deemed dividend addition u/s 2(22)(e) - gap of more than four years - when the amount received by the two concerns from the loan giver company was neither received by the petitioner nor was it for the benefit of the petitioner, such amount cannot be considered as deemed dividend in the hands of the petitioner, and consequently no income accrued to the petitioner from such transactions - in the absence of any failure on the part of the petitioner to disclose fully and truly all material facts necessary for his assessment, the reopening of assessment beyond a period of four years from the relevant assessment is without authority of law.....