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2015 (4) TMI 636 - HC - Income TaxUnaccounted sales - ITAT hold that the addition made of ₹ 1,35,00,000/- representing sale consideration and sustained by the Commissioner of Income Tax (Appeals) was sustainable in law or on facts? - Held that:- Tribunal took note of each of the adverse findings recorded against the appellant. In fact paragraphs 35-37 deal with other amounts and held that the sum of ₹ 15,15,000/- which was sustained by the CIT (Appeals) was unwarranted. Likewise, relief was granted in respect of addition of ₹ 20,00,000/- by the AO. Having regard to this conspectus of facts, the submissions of the assessee in this Court’s opinion amount to re-appreciation of circumstances at the third appellate level. Although, the interpretation of a document made in certain circumstances require interpretation of law, we are clear that in the overall circumstances of the case, given the concurrent nature of findings by the three authorities as far as the three amounts in question are concerned, at least no such question of law arises. As to whether the interpretation placed upon the document is such as to amount to patent error or not, in any case the interpretation given to the two documents in question and the inference drawn on the basis of the statements made are not such as to attract the jurisdiction of the Court which is confined to framing and answering substantial question of law. Since no such substantial question of law arises for consideration, the appeal is devoid of merit and is accordingly dismissed.
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