JUDGMENT

Manmohan, J. (Oral)--Present appeal has been filed challenging the order dated 26th February, 2019 passed by the ITAT in ITA No. 6892/DEL/2015. In the present appeal, the Principal Commissioner of Income Tax (`PCIT') has proposed the following questions of law:-

"i. Whether on facts and in the circumstances of the case the Hon'ble ITAT has not erred in law in dismissing the appeal filed by the revenue and upholding the order of CIT(A) in deleting the addition of Rs. 10,57,01,194/- made by AO under section 2(22)(e) of the Income Tax Act, 1961 in contravention of the law laid down by the Hon'ble Supreme Court in the case of Vikram Krishna Vs. PCIT (2020) 114 taxmann.com 197 (SC)?

ii. Whether in law and on facts of the case the order of the Hon'ble ITAT is not erroneous and not perverse?"

2. During the course of hearing, learned counsel for the appellant submits that the finding of the Commissioner, Income Tax Appeal [`CIT(A)'] and Tribunal are incorrect and bad in law and the finding of the Assessing Officer must be accepted, inasmuch as, the agreement between the parties was not registered and was made only on a stamp paper of Rs. 100/-.

3. Having heard learned counsel