assesse vehemently supported the impugned order,
and contended that the unsigned MOU and Supplement MOU by either of the parties and
being not corroborated with ... admitted facts on record that the disputed
seized MOU are unsigned documents by either of the parties to the agreement and therefore
Deputy Commissioner Of Income Tax, ... vs Pinnathevar Palanichamy, Madurai on 29 April, 2025
आयकर अपीलीय
Pinnathevar Palanichamy,Madurai vs Dcit, Cc-1(2), Chennai on 29 April, 2025
आयकर अपीलीय
price by the sellers from third parties.
Nothing turns on such unsigned MoU. The Ld. Counsel for the assessee
4|Page
ITA No.5652
termed as incriminating documents. Page No. 21-25 and 26 are
unsigned MOU between Subodh Kumar Gupta and Raj Kumar Chawla as
guarantee for transferring
imaginary hypothetical figures. In fact, it is
amply clear that the unsigned unregistered MOU's have just been submitted by the
assessee to give ... section 2(22)(e) of
the IT Act. Hence the unsigned and unregistered MOU's have no evidentiary
value.
6.4.4 Without prejudice
MoU dated 25 June 2019 raised on behalf of the Petitioner is
concerned, it is seen that copy of the alleged MoU does not show ... parties. Same is thus unsigned document.
Respondent No.2 has denied execution of such MoU. In that view of
the matter, it cannot be accepted
MoU dated 25 June 2019 raised on behalf of the Petitioner is
concerned, it is seen that copy of the alleged MoU does not show ... parties. Same is thus unsigned document.
Respondent No.2 has denied execution of such MoU. In that view of
the matter, it cannot be accepted
MoU dated 25 June 2019 raised on behalf of the Petitioner is
concerned, it is seen that copy of the alleged MoU does not show ... parties. Same is thus unsigned document.
Respondent No.2 has denied execution of such MoU. In that view of
the matter, it cannot be accepted
MoU dated 25 June 2019 raised on behalf of the Petitioner is
concerned, it is seen that copy of the alleged MoU does not show ... parties. Same is thus unsigned document.
Respondent No.2 has denied execution of such MoU. In that view of
the matter, it cannot be accepted