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TMI Blog2020 (1) TMI 298X X X X Extracts X X X X X X X X Extracts X X X X ..... n of two years in conformity with the mandate of Section 54B of the Income Tax Act. This was considered by the Commissioner as well as the Tribunal on the basis of the materials on record and a finding was rendered accordingly. This being the position, the finding rendered by the Commissioner, which was subjected to scrutiny and the finding given by the Tribunal is purely on a question of facts and no question of law is involved in this appeal; much less any substantial question of law. - TAXC No. 79 of 2018 - - - Dated:- 25-6-2019 - Per P. R. Ramachandra Menon, Chief Justice For Appellant: Ms. Naushina Afrin Ali, Advocate. Shri P. R. Ramachandra Menon, Chief Justice Shri Sanjay K. Agrawal, JJ. Ju ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hether on points of law and on facts circumstances of the case, the ITAT was justified in confirming the order of Ld. CIT(A) thereby giving a decision in favour of the assessee and against the revenue though there is no nexus between the conclusion of fact and primary fact upon which conclusion is based? 6. Whether on points of law and on facts circumstances of the case, the Hon'ble ITAT by upholding the order of CIT(A) has erred by giving a finding which is contrary to the evidence on record, as the Ld. CIT(A) has accepted the bills produced by the assessee towards the alleged agricultural activities, to be genuine and relied on other impugned documents produced before him by the assessee to be genuine, a finding which i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... elt aggrieved who approached the Tribunal by filing an Appeal, but turned to be unsuccessful, whereby the appeal came to be dismissed by the Tribunal. This is sought to be challenged by filing the present appeal under Section 260A of the Income Tax Act, raising the questions of law as extracted already. 6. The learned Standing counsel submits that the finding rendered is not in conformity with the law declared by the Hon'ble Supreme Court in Sarifa bibi Mohmed Ibrahim (Smt) Others. v. Commissioner of Income Tax, Gujarat; {(1993) Supp (4) SCC 707}. We have analyzed the merit of the said submission with reference to the materials on record. There is no dispute with regard to the law laid down by the Apex Court, as applicabl ..... X X X X Extracts X X X X X X X X Extracts X X X X
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