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2014 (8) TMI 682 - HC - Income TaxSale of detachable warrants (DW) - assessee claimed that since the cost of acquisition of detachable warrants is not ascertainable, the sale proceeds of these detachable warrants constitutes 'capital receipts not liable to tax - tribunal found that the assessee incurred cost of ₹ 9,94,356 for DWs allotted to it under the scheme – New Ground in appeal before High Court - Held that:- the first question, the third and the fourth questions framed at the time of admission, are on the question as to whether the findings of the learned Tribunal are perverse. We have enquired of Mr. Murarka to show that as to how are the findings perverse, to which his reply was that the relevant evidence was ignored. We requested Mr. Murarka to find out from the memorandum of appeal any ground alleging that any particular piece of evidence was ignored by the Tribunal. He replied that there is no such ground taken in the memorandum of appeal. He has even otherwise not been able to satisfy us that the view taken either by the Income-tax Officer or by the learned Appellate Tribunal is otherwise than on the basis of the evidence. The view taken both by the Income-tax Officer and the Income-tax Appellate Tribunal is a reasonable view in the facts and circumstances of the case. – Decided against Assessee.
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