SRI.PARAYARUKANDY VETTATH GANGADHARAN,CALICUT vs. THE DCIT CIRCLE-1(1), CALICUT

In the result, the instant appeal by the assessee is dismissed

Bench: Shri Sanjay Arora & Shri Manomohan Dasparayarukandy Vettath Gangadharan Dy. Cit, Circle - 1(1) Kerala Transport Company (Decd., Calicut Vs. Represented By Lrs.) K.T.C. Building, Ymca Calicut 673001 [Pan: Adhpg8318B] (Appellant) (Respondent)

u/s. 147 of the Act were initiated against individual partners, as the assessee, holding shares in the lender company/s, for AY 2007-08. Even as the assessee objected thereto, citing Board Circular (No. 459 dated 22.09.1987), the Assessing Officer (AO) assessed the deemed dividend at Rs.1,13,14,280/- relying on s. 150(1) of the Act, which provision reads