The High Court held that loan given by closely held company to concern in which shareholder of the company is substantially interested, cannot be taxed as deemed dividends in the hands of the concern but left it open to Revenue to tax it in the hands of the shareholder. The Revenue re opened the assessment beyond period of six years from the end of the relevant assessment year on the basis of observation of the Delhi High Court. On writ allowing the petition the Court held that observation of the High Court does not amount to a “direction” for section 150 purposes as it leaves it to discretion of Revenue. It cannot be called “finding” as it is not essential to adjudicate whether concern can be taxed or not. Even if it be a direction or finding, it is not an order by an authority under the Act as High court is not an authority. Section 150 will apply to appellate or revisional or reference order of High Court under any other Act. Assessment may be reopened beyond time u/s 150 to give effect to High Court orders passed under any other law but not to give effect to High Court’s orders passed under the Act. Reassessment notice was quashed. (AY. 2006-07)