Dismissing the appeal of the assessee the Court held that The assessee could not show what efforts were made by the Company and which bankers were approached for the loan. Therefore, in view of the above peculiar facts it is apparent that Agreement to Sell dated 8/6/2009 and cancellation of such deed by Agreement dated 1/8/2009 for the purchase of property is merely cover up and a camouflage for giving loan to the assessee by the above Company to avoid contravention of the provision of section 2(22)(e) of the Act. Assessee also failed to give the adequate evidence and cogent, reliable, and credible evidences about the transaction. The ld. CIT(A) has completely brushed aside finding of the A.O. in remand report and the statement of the assessee and further has not applied his mind to find out the true nature of the transaction. Accordingly the addition as deemed divided was affirmed.  (AY. 2010-11)