For Deemed Dividend, accumulated profits do not include current year’s business profit, since it accrues only at end of year

ITAT VISAKHAPATNAM BENCH P. Satya Prasad versus Income-tax Officer, Ward-3(2), Visakhapatnam IT Appeal No. 293 (Vizag.) of 2012 [ASSESSMENT YEAR 2007-08] NOVEMBER 16, 2012 ORDER B.R. Baskaran, Accountant Member The appeal of the assessee is directed against the order dated 29-06-2012 passed by LdCIT(A) and it relates to the assessment year 2007-08. 2. The grounds raised by the assessee give rise to the following two issues. (a) Validity of re-opening of assessment (b) Validity of assessment of deemed dividend u/s 2(22)(e) of the Act. 3. During the course of hearing, the Ld Co...