TMI Blog2008 (2) TMI 322X X X X Extracts X X X X X X X X Extracts X X X X ..... . - At the instance of revenue, the Income Tax Appellate Tribunal, Amritsar Bench, Amritsar (hereinafter referred to as 'the ITAT') has referred the following substantial question of law for the opinion of this Court which is stated to have been arising out of the order dated 26.02.1997 passed in ITA No.79 (ASR)/1991 in case of the assessee for the Assessment Year 1981-82:- "Whether, on the facts ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... premises of Shri J.C. Gupta and his family members certain incriminating documents were found and seized which indicated under statement of the cost of shares of M/s. Angoora Wool Combers sold to the family members of Nagesh Hosiery Mills (Ludhiana Group) with which the assessee was closely related and had purchased 650 shares at the cost of Rs.8/- per share on 02.01.1981, whereas the market value ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on of the assessee was not accepted and the Assessing Officer made the addition of Rs.91,884/- in the hands of the assessee as income from other sources while taking the value of the purchased shares @ Rs.149.36 per share. Feeling aggrieved against the above order, the assessee filed an appeal before the Commissioner of Income Tax (Appeals), Jalandhar, who vide its order dated 4.10.1990 allo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... milar issue was raised by the revenue in case of Shri Dharam Paul of Nagesh Hosiery Mills, Ludhiana, which came up for consideration before ITAT, Chandigarh in ITA No. 175(CHD)/1986 for the Assessment Year 1981-82. In that case, the value of the shares of M/s. Angoora Wool Combers Pvt. Ltd. was held to be @ Rs.8/- per share and the addition made by the Assessing Officer in case of the assessee per ..... X X X X Extracts X X X X X X X X Extracts X X X X
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