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2015 (10) TMI 753 - HC - Income TaxPayment out of undisclosed sources - Tribunal upholding the decision of the CIT(A) in deleting the addition of ₹ 4 lakhs made by the AO - Held that:- CIT(A) and the Tribunal by their orders have rendered finding of fact to the effect that the sum of ₹ 4 lakh mentioned in the impounded document had in fact been canceled along with the narration. Thus no cognizance of the same was taken as two authorities under the Act. This was on the basis of concurrent finding of fact holding that there is no such payment of ₹ 4 lakhs as mentioned in the impounded document as it has been canceled by the respondent assessee by drawing a line across the amount and the narration there much before impounding of the document. In view of the concurrent finding of facts not shown to be perverse and/or arbitrary, no substantial question of law arises for our consideration. Prorata deduction u/s 80IB(10) - Whether on the facts and in the circumstances of the case and in law, the Tribunal was correct in upholding the decision of the CIT(A) who allowed a prorata deduction u/s 80IB(10) of the Act ignoring the fact that the said section does not allow a prorata deduction u/s. 80IB(10) of the Act? - Appeal admitted on Question No.1.
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