During the course of the search, the Department seized cash to the extent of Rs. 35 lakhs from the residential premises of the petitioner.The petitioner offered the income of Rs. 35 lakhs seized from her residence as additional income for the assessment year 2013-2014 and also disclosed that the said income was derived out of the sale of Silver Oak trees which were felled at her agricultural lands. The petitioner had disclosed that she was a shareholder, holding more than 20% of equity share capital in each of the two Companies namely, M/s. Rasi seeds Private Limited (RSPL) and M/s. Rasi Tex India Private Limited (RTPL) and that RSPL had advanced monies in the ordinary course of its business as inter corporate loans to RTPL The Commission, through the impugned order dated 14.09.2015 held that the sum of Rs. 137,19,75,000/- advanced by RSPL to RTPL is to be assessed as deemed dividend in the hands of the petitioner, along with the income returned in each of the years and the additional income offered in the application. The five ingredients, as propounded by the Supreme Court in Tarulata Shyam's case (supra) to bring the said amount under the ambit of dividend are wholly satisfied in the present case and the four parameters, as enumerated by the Assessing Officer, are also squarely attracted to the case of the assessee herein. Therefore, any amount paid to the assessee by the company during the relevant year, less the amount repaid by the assessee in the same year, should be deemed to be construed as dividend for all purposes.