IN THE HIGH COURT OF DELHI AT NEW DELHI
1.
ITA 1299/2010
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CIT ..... Appellant
Through: Mr. Abhishek Maratha, Ms. Anshul
Sharma, Advs.
versus
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RPK BUILDERS PVT LTD ..... Respondent
Through: None
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CORAM:
HON'BLE THE CHIEF JUSTICE
HON'BLE MR. JUSTICE MANMOHAN
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O R D E R
07.09.2010
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Heard Mr. Abhishek Maratha, learned counsel for the revenue-appellant.
In this appeal preferred under Section 260A of the Income Tax Act, the
assail is to the order dated 13th August, 2009 passed by the Income Tax
Appellate Tribunal (for short ?the tribunal?) in ITA No.2048/Del/2008 pertaining
to assessment year 2005-06.
The singular question that arose before the CIT(A) as well as before the
tribunal was whether the addition of Rs.28,42,000/- by the assessing officer on
the ground that the said amount was in the realm of unexplained expenditure was
correct or not. Both the authorities, after referring to the facts in entirety,
have accepted the plea of the assessee. It is noticeable that the assessee has
purchased agricultural land from one Jagdish Kumar. The sale price was stated
to be Rs.90,24,000/-. The sale deed was executed on a recorded consideration of
Rs.61,82,000/- and the differential sum was shown as expenditure incurred for
leveling of land, filling of mud and other incidental expenses. It is worth
noting, the assessing officer called for the details and the assessee submitted
an affidavit from Jagdish Kumar who confirmed that he had received the payment
of Rs.90,24,000/- on different components. The assessing officer did not give
credence to the same and disallowed the expenditure. The CIT(A) noted that the
assessee had recorded in his books of account the whole consideration of sum on
two different dates. That apart, the amount was paid through account payee
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cheques and was fully verifiable from the record and was confirmed by the
seller. It has also been noted by the CIT(A) that the payment was made to the
seller as per the total agreed cost and, therefore, the same should have been
accepted. The CIT(A) as well as the tribunal treated the whole sum as the cost
of acquisition and accordingly came to hold that the disallowance made under
Section 69C of the Act was incorrect.
Mr. Maratha, learned counsel for the revenue-appellant submitted that
there was no evidence that the whole amount was paid to Jagdish Kumar for the
said purpose. In our considered opinion, the said submission does not deserve
any acceptation inasmuch as the amount was paid to Jagdish Kumar from whom the
property was purchased and was developed. The amount was paid by account payee
cheques and was reflected in the books of account.
In view of the aforesaid, we are of the considered opinion that no
substantial question of law arises for consideration and, accordingly, the
appeal, being sans merit, stands dismissed in limine.
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CHIEF JUSTICE
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MANMOHAN, J
SEPTEMBER 07, 2010
pk
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