Court Upholds ITSC Order on Deemed Dividends u/s 2(22)(e); Revenue's Concerns Addressed in Settlement.

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....Validity of order of Income Tax Settlement Commission [ITSC] - deemed dividend under Section 2(22)(e) - The Revenue need not have any apprehension over the income, which was initially disclosed at the time of filing the application under Section 245C of the Act because the said income, which was offered at the first instance was not accepted by the Revenue and a report under Rule 9 of the said Rules was filed and based on that, the Revenue suggested four additions and thereafter, the case was proceeded and the matter was settled. - HC....