Sec. 2(22) of the Income-tax Act, 1961 - Deemed dividend - The assessee is aggrieved by an order of the ITAT, which upheld the AO's determination with respect to the addition made for A.Y. 2010-11 under section 2(22)(e) of the Act, 1961. High Court dismissed the appeal of the assessee holding that ”the ITAT's decision is based upon an independent analysis of the facts. No doubt it differed from the CIT(A)'s view. At the same time all its findings are based upon appreciation of material facts. Its conclusion are a possible view that can be taken by the Tribunal based upon the circumstances. The acceptance of one view on facts as against another, unless it showed to be wholly unreasonable, cannot be subject matter of an appeal under section 260A of the Act“. Supreme Court dismissed SLP against the order of High Court. - VIKRAM KRISHNA V/s PR. CIT - [2020] 269 TAXMAN 477 (SC)