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2017 (9) TMI 1713 - GUJARAT HIGH COURTAdditions on account of unexplained investment in properties - seized document could be treated as corroborative evidence or not - addition u/s 2(22)(e) towards deemed dividend - Held that:- the case of the Revenue is that certain loose documents were found during search representing the assessee's cash transactions recorded in terms of rupees in crores. The assessee, however, denied this suggesting that these figures represented the calculations for the purpose of vastu shastra. CIT (Appeals) as well as the Tribunal concurrently held that there was no material suggesting that the figures indicated in loose papers represented assessee's cash transactions. This was thus purely a question of fact. No question of law therefore arises. Second question pertains to deemed dividend under section 2(22)(e) of the Act. The Tribunal found that there was no material found during the survey relatable to this issue and therefore confirmed the view of the CIT(Appeals). - Revenue appeal dismissed.
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