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2015 (11) TMI 1810 - AT - Income TaxTaxing the entrance fees collected - Revenue or capital receipt - certain loose papers were found at assessee’s premises on the basis of which the AO inferred that assessee had given ₹ 50 lakhs to Sujan Parikh group - CIT(A) deleted the addition - HELD THAT:- A categorical finding has been recorded by the CIT(A) to the effect that no additional amount was paid, the amount so paid was part and parcel of the total consideration paid to Shri Sujan Parikh. From the record we found that Mr. Sujan Parikh has received the consideration for transfer of shares of NPCL in direct proportion of the market value of the properties held by NPCL in the month of April 2006. There was no mention of any additional amount of ₹ 50 lakh. There was no other mention anywhere in the correspondence exchanged for family settlement which indicated that Mr. Sujan Parikh was paid ₹ 50 lakh extra over and above the consideration paid for sale of shares in the group companies. As per finding of the CIT(A) no cogent material was brought on record by the AO to hold that ₹ 50 lakhs was paid in addition to normal consideration so determined. Accordingly, we do not find any infirmity in the order of CIT(A) for deleting the addition of ₹ 50 lakhs - Appeal of revenue is dismissed.
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