2014 (8) TMI 1135

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..... been enlarged by a legal fiction which does not extend to ‘shareholder’. In this case, the respondent assessee is not a shareholder of M/s. Pataka Industries Ltd. - Decided in favour of assessee. - G.A. No. 2394 of 2014 And ITAT No. 122 of 2014 - - - Dated:- 21-8-2014 - Soumitra Pal, And Arindam Sinha, JJ. Order The Court : The other matters appearing along with this matter are delink .....

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..... justified in law in dismissing the appeal of the revenue by relying upon the decision of the Hon'ble Rajasthan High Court in the case of CIT vs. Hill Top reported in 313 ITR 116 wherein it has been held that section 2(22)(e) cannot be invoked in the case of an assessee who is not a shareholder. Heard Ms. Das De, learned advocate for the appellant and Mr. Khaitan, lerned senior advocate f .....

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