Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2019 (4) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (4) TMI 572 - HC - Income TaxDisallowance u/s 40A(3) - cash payments exceeding permissible limits - CIT(A) affirmed the said addition considering a case of splitting of entries which had been done to avoid the provisions of Section 40A(3) - assessee took two months, and took 9 dates for submitting revised copy of account - Tribunal confirmed addition stating submissions of the assessee cannot be accepted as no attempt had been made to demolish the conclusions drawn on facts - scope of findings of fact - HELD THAT:- An effort was made by learned counsel for the appellant to demonstrate that the conclusions and the concurrent finding of facts recorded by the Assessing Officer, the CIT(A) and the Tribunal was erroneous and perverse by referring to the copy of evidence produced before us, but the appeal under Section 260A of the Act lies only on a substantial question of law. The appreciation of evidence to arrive at different conclusion on the same evidence does not fall within the ambit of substantial question under Section 260A of the Act. The aforesaid findings of fact recorded by the Assessing Officer, the CIT(A) and the Tribunal, thus, cannot be held to be perverse based on non-appreciation of material on record or based on misreading of any evidence on record which may warrant interference by this Court. No question of law, much less, substantial question of law arise in the appeal. - Decided against assessee.
|