2021 (8) TMI 835 - SCH - Income Tax

Reopening of assessment u/s 147 - deemed dividend addition u/s 2(22)(e) - gap of more than four years - failure on the part of the petitioner to disclose fully and truly all material facts necessary for his assessment - second mode of payment envisaged under clause (e) of section 2(22) viz. to any concern in which such shareholder is a member or a partner and in which he has substantial interest - HC held 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 - HELD THAT - SLP dismissed.

Summary

The Supreme Court of India dismissed the Special Leave Petition as they found no ground to interfere with the impugned order passed by the High Court. Pending interlocutory application(s) were disposed of.