TMI Blog2017 (6) TMI 403X X X X Extracts X X X X X X X X Extracts X X X X ..... uestion of appreciation of evidence, and no question of law arises for our consideration under Section 260A. - I.T.T.A. Nos. 54 and 55 of 2017 - - - Dated:- 13-4-2017 - V. Ramasubramanian And J. Uma Devi, JJ. JUDGMENT ( Per VRS, J ) The assessee has come up with these appeals under Section 260A of the Income Tax Act, 1961. 2. Heard Mr. A.V. Raghuram, learned counsel for the appe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and others, at the rate of ₹ 32.00 lakhs per acre. An amount of ₹ 3.9 crores had been paid as an advance as on 18.11.2006. 5. As on the date of the survey, the appellant and others had paid an amount of ₹ 4.9 crores. The appellant sought to explain his share of ₹ 1,22,50,000/-, out of the said payment of ₹ 4.9 crores, by claiming that he invested his own funds to t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t ₹ 4.9 crores as claimed by them. 7. The appeal filed by the assessee/appellant was partly allowed by the CIT (Appeals). The assessee as well as the Department filed appeals before the I.T.A.T. The I.T.A.T. allowed the appeal of the Department and dismissed the appeal of the assessee. Therefore, the assessee is before us in these two appeals. 8. The main ground of attack to the order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rsons. The Tribunal found it hard to believe that all those seven persons at about the same time received the sale proceeds and invested the same in cash with the appellant. Therefore, it was a question of appreciation of evidence, and no question of law arises for our consideration under Section 260A. Hence, both the appeals are dismissed. Consequently, miscellaneous petitions if any pending i ..... X X X X Extracts X X X X X X X X Extracts X X X X
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