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2019 (7) TMI 429 - AT - Income TaxExemption u/s 11 denied - Sale consideration for assignment of lease - Accrual on Income - AO found that the assessee had sold immovable property however the assessee failed to disclose this transaction while filing its return of income for the impugned assessment year - HELD THAT:- The grounds of appeal filed by the assessee can be seen through the lens of deductive inference, in which it is asserted that the conclusion is guaranteed to be true if the premises are true. In the present case, it is the contention of the assessee vide the 2nd ground of appeal that the Ld. CIT(A) failed to note that the amount of ₹ 3,55,45,600/- was not factually received during the year under appeal. This premise is not true as evident from the finding above that the assessee has received ₹ 3,55,45,600/- during the financial year 2010-11 relevant to the impugned assessment year. The inference drawn by the assessee is not a correct one as it is based on wrong premise. In view of the above facts and position of law, we uphold the order of the Ld. CIT(A) in holding that the amount accrued to the Appellant as income for the year under appeal and was also received. - Decided against assessee.
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