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TMI Blog2023 (8) TMI 964X X X X Extracts X X X X X X X X Extracts X X X X ..... tion but the Assessing Authority, Appellate Authority and ITAT all recorded concurrent finding placing reliance mainly on the sale deed and recital contained therein. Moreover, it is not the case of the appellant-assessee that the entire sale consideration was transferred in the account of the assessee through cheque issued by the purchasers. It is a case of cash deposit. Therefore, the burden was on the assessee to prove that the consideration for sale was Rs. 20,80,000/- and not what was recited in the sale deed. We find that all the authorities have appreciated the oral and documentary evidence and recorded their findings of fact on the issue as to what actually was the sale consideration in the matter of transaction of sale of agr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal preferred, the appeal was also dismissed. When the assessee filed an appeal before the Income Tax Appellate Tribunal which was also dismissed holding that the evidence on record proved that the total amount of consideration out of the sale of agriculture land was only Rs. 6.75 lacs and the appellant s case that the sale consideration in Rs. 20,80,000/- was rejected. 4. Learned counsel for the appellant argued that the finding of the learned Tribunal is perverse and opposed to law. His submission is that in support of its case of sale consideration of Rs. 20,80,000/-, the appellant relied upon the registered sale deed which exhibited market value and payment of stamp duties therein which is proportionate to the income as claimed by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ration for sale was Rs. 20,80,000/- and not what was recited in the sale deed. 6. Be that as it may, we find that all the authorities have appreciated the oral and documentary evidence and recorded their findings of fact on the issue as to what actually was the sale consideration in the matter of transaction of sale of agricultural land. Even though the submission of learned counsel for the appellant would be that there was no proper appreciation of evidence, it is essentially a case of appreciation of evidence and not of substantial question of law. As the appeal does not involve any substantial question of law, we are not inclined to re-appreciate and interfere with the concurrent finding of facts recorded by the all the authorities in ..... X X X X Extracts X X X X X X X X Extracts X X X X
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