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2013 (10) TMI 1416 - HC - Income TaxAdditional sale consideration received in respect of property - Undisclosed income - Held that:- The law on the subject is well-settled. The Revenue where it seeks to make an addition as representing undisclosed income of the Assessee, may do so on the basis of reliable material. An addition cannot be made on surmises or on the basis of hypothetical assumption. In the present case, the finding of fact by the first appellate Authority was that there was no supporting evidence available other than the seized e-mail to arrive at a conclusion that the amount of ₹ 6,60,00,000/- was an additional undisclosed income. The Tribunal, in appeal, has accepted the view of the CIT(A), while holding that the additions have been correctly deleted. We do not find that the findings of facts which have been arrived at by the first appellate Authority and which have been confirmed by the Tribunal, suffer from any perversity to warrant interference in appeal under Section 260A
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