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TMI Blog2021 (12) TMI 716X X X X Extracts X X X X X X X X Extracts X X X X ..... d by the authorities below before passing the impugned orders. The ITAT also held that the scrips of M/s CCL International Ltd. were freely traded at the Bombay Stock Exchange between the years 2011 and 2014 and the assessee had purchased the shares in 2011 and sold the same in 2012. ITAT also found that the revenue from the operation of M/s CCL International Ltd. from March, 2010 to March, 2012 w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n set of circumstances two inferences of fact are possible, the one drawn by the lower appellate court will not be interfered by the High Court in second appeal. Adopting any other approach is not permissible. It has also held that there is a difference between question of law and a substantial question of law . Consequently, this Court finds that there is no perversity in the findings of the ITAT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... TAT failed to appreciate that the transaction entered by the assessee for purchase of shares of CCL International Ltd. are in the nature of bogus or colourable transaction resulting in huge capital gain to the assessee. He states that the ITAT erred in holding that to prove a bogus or colourable Transaction there has to be an individual inquiry by the Assessing Officer ignoring the fact that the A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the Bombay Stock Exchange between the years 2011 and 2014 and the assessee had purchased the shares in 2011 and sold the same in 2012. The ITAT also found that the revenue from the operation of M/s CCL International Ltd. from March, 2010 to March, 2012 was between ₹ 55.25 crores to ₹ 79 crores and the share price during the period 2010 to 2014 had increased from ₹ 50 per shar ..... X X X X Extracts X X X X X X X X Extracts X X X X
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