TMI Blog2019 (7) TMI 1392X X X X Extracts X X X X X X X X Extracts X X X X ..... ound in some file extracted from the computer of Sh. Rohtash, clearly establish that the provisions of section 69A of the Act do not apply. It was further found that on the date of receipt of the impugned amount, the same was returned to the Amrapali Group by the M/s Bihari Ji Group. The determination by the ITAT is based on facts and there is nothing to indicate that it is perverse. Unexplai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rent or hire charges were in fact paid to either of the above entities. Before the ITAT, the Revenue was unable to show anything to the contrary. This too being a purely factual determination concurrently by the CIT (A) and the ITAT in favour of the Assessee - No substantial question of law. - ITA 586/2019 - - - Dated:- 23-7-2019 - S. MURALIDHAR AND TALWANT SINGH JJ. Appellan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 23;) and observed that one of the primary requirements for attracting that provisions is that the Assessee is found to be owner of any money, bullion, jewellery or other valuable article . 4. On facts, the ITAT had found that the Assesee was never found to be in possession of any real money. The addition having been made only on the strength of some notings found in some file extracted ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rce of money used for payment to the Assessee was unaccounted. This again is a factual determination and does not give rise to any substantial question of law. 7. The third issue is whether the ITAT was right in deleting the addition of ₹ 5 lakhs on account of disallowance of bogus‟ expenses? 8. The ITAT noted that the said addition was made on the premise that the A ..... X X X X Extracts X X X X X X X X Extracts X X X X
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