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DELHI HIGH COURT
MANMOHAN, DINESH KUMAR SHARMA
Pr. Commissioner of Income Tax (Central)-2 – Appellant
Versus
Imperial Housing Ventures P. Ltd. – Respondent
| Table of Content |
|---|
| 1. challenge to itat decision regarding unexplained expenditure. (Para 1 , 2) |
| 2. concurrent factual findings on the genuineness of purchases. (Para 3 , 4) |
| 3. dispute on the application of section 69c based on evidence. (Para 5) |
| 4. no question of law arises; appeal dismissed. (Para 6) |
JUDGMENT
Manmohan, J. (Oral)--Present appeal has been filed challenging the order dated 26th August, 2020 passed by ITAT in ITA No. 6448/Del/2015 for the Assessment Year 2011-12.
2. Learned counsel for the Appellant states that ITAT has erred in upholding the decision passed by CIT(A), whereby it has deleted the addition made by the Assessing Officer amounting to Rs.7,17,95,500/- as `unexplained expenditure' in complete disregard of the system of accounting and the applicable accounting standards.
3. Having perused the paper book, this Court finds that in the questions of law framed by appellant the emphasis is on the factum that the entities from whom the purchases had been shown to have been made by the respondent-assessee were bogus and non-existent, on the ground that such entities were not found existing during the search and post search proceeding.
4. However, both, CIT(A) as we
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