TMI Blog2000 (8) TMI 24X X X X Extracts X X X X X X X X Extracts X X X X ..... ), the order of the Income-tax Appellate Tribunal (in short "the Tribunal"), passed in I. T. A. No. 810/Delhi of 1997 dated February 26, 1999, is under challenger The relevant assessment year is 1991-92. The background facts are as under : The original assessment had been completed under section 143. But subsequently proceedings were initiated under section 147 of the Act on the basis of certa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t is crystal clear that Rs. 16 lakhs has been received by the asses see for the assessment year in cash and outside the books. Both the persons have made payment against the property and the receipt in the hands of the assessee-company becomes the revenue received and is income charge able to tax. On the basis of this piece of information I have reason to believe that Rs. 16 lakhs being income cha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ons recorded for reopening of the assessment are concerned the quoted portion goes to show that reasons did exist for entertaining a belief that income chargeable to tax had escaped assessment. Additionally, the conclusions of the Tribunal on the question whether there was any receipt beyond the books are essentially factual and have been rendered after taking into account relevant aspects. That b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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