TMI Blog2017 (11) TMI 74X X X X Extracts X X X X X X X X Extracts X X X X ..... r specific purposes where the assessee had functioned as a contractor or mediator on behalf of or at the request of two commercial entities. Having taken into account the actual status of the accounts, records, bills and vouchers, the ITAT came to the conclusion that the appeal of the Revenue called for no interference. We are unable to see any infirmity in the order of the ITAT and certainly we are unable to see how it raises any question of law at all. This is not a matter of a complete misappreciation of the records or evidence. The Commissioner in the appeal before him took a view. The ITAT held that view to be plausible. It noted no perversity. We find no perversity either in the order of the ITAT. Certainly it cannot be said that o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e substantial ones. 3. The assessee, the father of the present Respondent, was a real estate agent. The appeal is directed against an order dated 9th August 2016 of the Income Tax Appellate Tribunal, Panaji bench. This was in respect of two Assessment Years 2006-07 and 2007-08. It seems that a search and seizure was conducted on 16th April 2010 under Section 132(1) of the Income Tax Act. Some material was found relating to the assessee and this, according to the Revenue showed a nexus between the assessee and his son, the present Respondent. 4. A notice under Section 153C of the Income Tax Act dated 21st November 2012 was issued and served. The assessee, Venkaraddi Kittur filed a nil return. Notices under Sections 142(1) and 143(2) da ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ench found that the Commissioner had followed well-settled principles. In regard to non-proving of expenditure, the Commissioner found that all transactions were banked. The ITAT held that the Revenue in appeal was unable to dislodge the findings that the so-called assets in the hands of the assessee were agricultural land and not capital assets. It also found that there were known sources of income and these were for specific purposes where the assessee had functioned as a contractor or mediator on behalf of or at the request of two commercial entities. Having taken into account the actual status of the accounts, records, bills and vouchers, the ITAT came to the conclusion that the appeal of the Revenue called for no interference. 6. We ..... X X X X Extracts X X X X X X X X Extracts X X X X
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