Substantial Shareholding Date Under IT Act Sec 2(22)(e) Valid if Filed Late with ROC Acceptance.

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....Deemed dividend u/s 2(22)(e) - effective date for determination of substantial share holding - one can file belated return with the ROC along with "late fee" as applicable, as was done by assessee and since the same was accepted by the ROC, hence, for all intents and purposes, the effective date of transaction will be the date as mentioned in the return.....