JUDGMENT

A.K. Sikri, J. In all these appeals, same questions of law touching the interpretation that is to be accorded to the provisions of Section 2(22)(e) of the amount received by the Income Tax Act (hereinafter referred to as `the Act'), arise for consideration. Our purpose would be served by taking note of the questions of law framed in ITA No.462 of 2009, as concededly answer thereto shall cover the outcome of all these appeals. The substantial questions of law on which this appeal was admitted are as under:

"a) Whether ITAT was correct in law in deleting the addition of Rs.6,32,72,265/- made by the Assessing Officer in the hands of assessee company under Section 2(22)(e) of the Act?

b) Whether ITAT was correct in law in holding that the addition could not have been made by the Assessing Officer in the assessee company as it was not the shareholder of M/s Jackson?

c) Whether ITAT has correctly interpreted the provisions of Section 2(22)(e) of the Act?

d) Whether order passed by ITAT is perverse in law and on facts when it deleted the addition holding that though the amount received by the assessee by way of book entry falls within the ambit of Section 2(22)(e) of the