TaxTMI 
TaxTMI 
2008 (4) TMI 232
X X X X Extracts X X X X
X X X X Extracts X X X X
....passed by the Income Tax Appellate Tribunal, Delhi Bench "E", New Delhi ("the Tribunal") in I.T.A. Nos. 3857/Del/2003, 3256/Del/2003 and CO No.203/Del/05 in I.T.A. No.3857/Del/2003 relevant for the Assessment Year 1996-97. 2. The only issue in this appeal is whether reassessment proceedings initiated under Sections 148/147 of the Income Tax Act, 1961 (the Act) were valid in law. 3. The Assessing....
X X X X Extracts X X X X
X X X X Extracts X X X X
....8,192/- has escaped assessment (done under Sections 143(3)). Notice u/s 148 be issued Additional CIT/Range 5 may kindly see" 4. The sum and substance of the contention of the learned counsel for the Revenue was that the Assessee had received loans from M/s Mokul Overseas Pvt. Ltd. and these loans were really in the nature of deemed dividend as defined under Section 2(22)(e) of the Act. 5....
X X X X Extracts X X X X
X X X X Extracts X X X X
....td. also mentions its Pan number and Circle where it was assessed; the books of accounts of the Assessee were produced on more than one occasion before the Assessing Officer; it was also mentioned that an amount of Rs.1,96,68,192/- was received by the Assessee as an unsecured loan from M/s Mokul Overseas Pvt. Ltd.; the tax audit report was also filed by the Assessee. The Tribunal noted that the De....