Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2020 (1) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (1) TMI 298 - HC - Income TaxDisallowance of deduction u/s 54B - ITAT confirming the deletion by the CIT(A) of the addition by the AO on account disallowances of deduction u/s 54B - HELD THAT:- Appellant did not make any specific reference (in the manner in which the appeal has now been moulded before this Court) to be considered by the Commissioner of Income Tax (Appeals) or by the Tribunal. The submission before the Commissioner as well as the Tribunal was all with reference to the factual aspect as to the necessity to have the agricultural operation in the property concerned which was subjected to sale within the span of two years in conformity with the mandate of Section 54B of the Income Tax Act. This was considered by the Commissioner as well as the Tribunal on the basis of the materials on record and a finding was rendered accordingly. This being the position, the finding rendered by the Commissioner, which was subjected to scrutiny and the finding given by the Tribunal is purely on a question of facts and no question of law is involved in this appeal; much less any substantial question of law.
|