Amount advanced for supply Material/Labour cannot be treated as deemed dividend U/s. 2(22)(e)

Brief of the case: In the case of Smt. Uppala Rajani Vs. DCIT Hyderabad Bench of ITAT have held that the amount advanced for business transaction between parties regarding supply of material and labour, are not such to fall within the definition of ‘deemed dividend’ under S.2(22)(e). ITAT Also adjudicated issue of reopening and held that reopening was based on information revealed out during survey and also statements were recorded at the time of survey. So it can not be said that reopening was based on change of opinion if earlier order was passed u/s 143 (3). Facts of the Case: The asse...