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2012 (10) TMI 96 - HC - Income TaxUndisclosed income - Held that:- Whether particular transaction involves the investment or not is the question of fact and the CIT(Appeal), recorded the finding that A.O. had no reason at all to treat entire purchases as unexplained investment and it was a purely imagination of the A.O. So far as the estimation of the income is concerned, for that also, cogent reason has been given by the CIT(Appeal) as well as considered by the Tribunal. The considered opinion that the question of facts have been decided by the CIT(Appeal) as well as by the Tribunal after appreciation of the evidences which have not been vitiated because of non-consideration of the material evidence, nor because of consideration of irrelevant evidence, nor the findings recorded by these two authorities can be said to be perverse - no substantial question of law.
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