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2019 (5) TMI 185 - AT - Income TaxRectification u/s 254 - Unexplained investment u/s 69 - payments falling in the financial years prior to the financial year 2004- 05 relevant to assessment year 2005-06 - HELD THAT:- In this case, the transaction entered into viz., “agreement of sale of undivided share of land and department store to be constructed with Aadhithiya Constructions” is single property spread over to various years is not under dispute. If it is so, when the sources are in question, the said sources are to be seen for the property as a whole and thus, the Tribunal sustained the observations of the ld. CIT(A) and rejected the alternative plea raised by the assessee. Thus, we find no mistake apparent on record and accordingly, the petition filed by the assessee stands dismissed.
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