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TMI Blog2016 (7) TMI 531X X X X Extracts X X X X X X X X Extracts X X X X ..... any question of law, much less a substantial question of law, and therefore, requiring no interference on our part. Resultantly, the present appeal is dismissed with no order as to costs. - Decided against revenue - I. T. A. No. 294 of 2014 - - - Dated:- 8-7-2016 - MR. S. J. VAZIFDAR AND MR. DEEPAK SIBAL, JJ. For The Appellant : Mr. Denesh Goyal, Advocate For The Respondent : Mr. Sunil Mukhi, Advocate and Ms. Prerna, Advocate DEEPAK SIBAL, J. : Invoking the provision of Section 260-A of the Income Tax Act, 1961 (hereinafter referred to as the Act), the Revenue has preferred the instant appeal laying a challenge therein to the order dated 12.02.2014 (Annexure A-3) passed by the Income Tax Appellate Tribunal, Amritsar ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ement pertained to sale and purchase of about 68.45 acres of land and according to the same, in pursuance thereof, the assessee had received ₹ 5 crores from the Company, out of which ₹ 70 lacs had been received in cash. Resultantly, notice under Section 143-C of the Act was issued to the assessee, in response to which, a reply was filed. The books of accounts of the Company were compared with that of the assessee and the Assessing Officer, finding the afore-referred amount of ₹ 70 lacs to be unaccounted for, ordered addition of the same to the income of the assessee. The order to make such addition was taken up in appeal by the assessee before the Commissioner of Income Tax (Appeals), Amritsar (hereinafter referred to as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the farmers and such receipt could, at the most, be treated as a capital receipt, but in no circumstance, the same could be added to the income of the assessee, especially when the same had already been added to the income of the Company. The Tribunal further noticed that the agreement, which had been recovered from the afore-referred Vipin Verma, between the Company and the assessee, was for a total amount of ₹ 5 crores, out of which, the Commissioner held that for ₹ 4.30 crores, the assessee had purchased land on behalf of the Company and accordingly ordered the addition of commission @ 2% on ₹ 4.30 crores to the already assessed income of the assessee. It was held that once the Commissioner came to such a conclusion, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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