TMI Blog2008 (8) TMI 497X X X X Extracts X X X X X X X X Extracts X X X X ..... donation from 46 donors. All the 46 donors had purchased the land, which they had gifted, through registered sale deeds sometimes during the period 1992-94. They had gifted the land by way of registered gift deeds and the value of the plots so gifted came to be Rs. 3,35,39,387. The assessee incurred an expenditure of Rs. 49,51,161 towards purchase of stamp papers and registration charges for execu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... could not be added under the head “Income from other sources”. (iii) That with regard to the sum of Rs. 5,50,000/- it had to be noted that the assessee was a very big trust and had a large following and if on some occasion it had distributed some cash to poor persons it could not be said that the expenditure was not incurred; more so when the Tribunal had recorded a finding that the expenditure w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... received 111 plots of land by way of gift/donation from 46 donors. All the 46 donors had purchased the land, which they had gifted, through registered sale deeds sometimes during the period 1992-94. They had gifted the land by way of registered gift deeds and the value of the plots so gifted came to be Rs. 3,35,39,387. The assessee incurred an expenditure of Rs. 49,51,161 towards purchase of stam ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rchased the plots of land through registered sale deeds and the same were mutated in their names and sub sequently out of love and affection they have donated the land to the assessee-trust through registered gift deeds though the expenses on registration charges and stamp papers were incurred by the assessee. There is no question of unexplained investment in the acquisition of the plots in questi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n it has distributed some cash to the poor persons it cannot be said that the expenditure was not incurred; more so, when the Tribunal has recorded a finding that the expenditure was actually incurred. 9. In view of the foregoing discussions, we are of the opinion that the findings recorded by the Tribunal do not give rise to any substantial questions of law as they are based 'on appreciation of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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