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1) There is no evidence to establish the 'personal' and 'intimate' and 'proximate' bond existing between the paintings sold during the year and 'the person' of the assessee. Thus there are no facts on records justifying the claim of 'personal effect' with respect to sale of paintings and thus, the claim was rightly not entertained by the CIT(A) in the absence of a valid revised return.
m) The year-wise position of number of paintings sold and alleged mode of acquisition of those paintings is as under: