9911796707
TMI Blog1993 (3) TMI 68X X X X Extracts X X X X X X X X Extracts X X X X ..... income-tax. We, are concerned with the assessment year 1982-83, for which the accounting period ended on March 31, 1982. In this original petition the Revenue prays for a direction to the Income-tax Appellate Tribunal, Cochin Bench, to refer the following two questions of law for the decision of this court "1. Whether, on the facts and in the circumstances of the case, (a) the Tribunal is just ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1981) dated May 14, 1981, the assessee purchased certain immovable properties on the side of M. G. Road for a consideration of Rs. 4,76,000. In spite of notices, the assessee did not explain the source of the investment. The Income-tax Officer also held that the assessee had to meet his personal and household expenses and taking into account these facts, the total income of the assessee was estima ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... der of the Appellate Tribunal is laconic. We are not in a position to fully understand the implications of the said order. Be that as it may, admittedly, the assessee has purchased properties for a sum of Rs. 4,76,000 during the accounting period. It is for him to explain the source of his investments. He did not respond to the various notices sent by the Income tax Officer. Placing reliance on su ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... apart, the order of the Appellate Tribunal does not show as to why it held that the assessment is arbitrary. The relevant facts have been stated in the appellate order. What are the details that are lacking therein and what further aspects are to be adverted to by the Income-tax Officer before making the best judgment assessment under section 144, are not adverted to nor stated by the Appellate T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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