2019 (2) TMI 728

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..... as it does not give any particulars of the persons involved in the alleged transaction. Thus, it is not open to the Assessing Officer to draw inferences from the document by interpreting the words “Sh” to mean cash payment and “Q” to mean cheque payment without any evidence on record. The CIT(A) as well as the Tribunal have concurrently rendered a finding of fact, which is not shown to be perverse .....

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..... 3. The Assessing Officer reopened the assessment for A.Y. 200708. This consequent to information obtained during the course of search operation conducted in the case of Bharat Shah Group, which was engaged in real estate business. In the course of raid, certain loose papers were found which related to the sale transactions of flats. The respondent assessee is an individual who declared a total .....

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..... on by the Assessing Officer did not have any signature nor contain name of the assessee nor did it mention the rate at which the flat was sold. Further, the builder as well as the respondent assessee had denied that any payments were made and / or received in cash in purchase of the flat. Thus, it held that no reliance can be placed on such documents to conclude that the respondent had made paymen .....

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