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TMI Blog2021 (12) TMI 829X X X X Extracts X X X X X X X X Extracts X X X X ..... transaction with regard to the shop in the Cross River Mal? - HELD THAT:- This Court finds that the name of the assessee nowhere appears in the computer generated loose sheets found from the residence of Mr.Lalit Modi, the alleged broker. ITAT in its impugned order has concluded that there was no corroborative evidence or statement to prove that the payment had been received by the assessee other ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... easoning to deviate from the findings recorded in the assessment order that the Respondent had failed to discharge its onus to prove the genuineness of the sale transaction with regard to the shop in the Cross River Mall. 3. Learned Counsel for the Appellant states that the impugned order is erroneous as it fails to appreciate that the seized material indicated that certain portion of the transac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... enue's failure to satisfy the jurisdictional benchmark of 'belong to' under Section 153C of the Act. However, she states that the Tribunal failed to appreciate that in the present case, the assessing officer having jurisdiction over the respondent had duly recorded his satisfaction that the seized material belonged to the respondent. 5. Having heard learned counsel for the appellant, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dismissed a similar appeal filed by the Revenue being ITA No.1104/2020. Further, the Division Bench in the said case had not only dismissed the appeal on the ground of jurisdiction but also on merits. 9. A Special Leave Petition filed against the said judgment has also been dismissed by the Supreme Court. 10. Consequently, this Court is of the view that no substantial question of law arises for ..... X X X X Extracts X X X X X X X X Extracts X X X X
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