9. The issue of whether the common approval granted
u/s.153D is a valid approval or not, came up for consideration
Page | 6
before the Hon'ble Delhi High Court in the case of Shiv Kumar
Nayyar (supra).
9. The issue of whether the common approval granted
u/s.153D is a valid approval or not, came up for consideration
Page | 6
before the Hon'ble Delhi High Court in the case of Shiv Kumar
Nayyar (supra).
9. The issue of whether the common approval granted
u/s.153D is a valid approval or not, came up for consideration
Page | 6
before the Hon'ble Delhi High Court in the case of Shiv Kumar
Nayyar (supra).
9. The issue of whether the common approval granted
u/s.153D is a valid approval or not, came up for consideration
Page | 6
before the Hon'ble Delhi High Court in the case of Shiv Kumar
Nayyar (supra).
In the case of Asstt. CIT v. Anoop Kumai (supra), the Tribunal (SMC), Amritsar Bench referred to the judgment of Hon'ble Andhra Pradesh High Court in the case of CIT v. Ramdas Motor Transport (2000) 163 CTR (AP) 403 : (1999) 238 1TR 177 (AP) where it was held that the confessional statement without there being any documentary proof cannot be used in evidence against the person, who made such statement.
5. Aggrieved, the assessee filed an appeal before the CIT (A). It
was contended that the land was purchased by the assessee for a sum
of ` 69,18,900/- during financial year 2003-04 which was registered
during financial year 2004-05. No amount other than the amount
mentioned in the title deed was paid by the assessee for purchase of
land. The copy of sale deed was furnished for verification of the
Assessing Officer. No evidence whatsoever was found either during
the course of assessment proceedings or during the course of survey.
That any amount extra than the amount declared in the purchase deed
was paid by the assessee to the seller. Therefore, it was contended
that the Assessing Officer had no positive evidence indicating the fact
that the assessee has paid anything more than the one disclosed in the
sale deed. Reference was made to the decision of Hon'ble Supreme
Court in the case of K.P. Verghese 131 ITR 597 (SC) and also the
decision of Hon'ble Delhi High Court in the case of CIT vs. Mahesh
Kumar (ITA No.1191-1192/2010).