PR. COMMISSIONER OF TAX Vs. ANUMOD SHARMA

JUDGEMENT

(1.) Present appeal has been filed challenging the order dtd. 26/2/2019 passed by the ITAT in ITA No. 6892/DEL/2015. In the present appeal, the Principal Commissioner of Income Tax ('PCIT') has proposed the following questions of law:-

(2.) During the course of hearing, learned counsel for the appellant submits that the finding of the Commissioner, Income Tax Appeal ['CIT(A)'] and Tribunal are incorrect and bad in law and the finding of the Assessing Officer must be accepted, inasmuch as, the agreement between the parties was not registered and was made only on a stamp paper of Rs.100.00 .

(3.) Having heard learned counsel for the appellant, this Court finds that the issue canvassed during the hearing is not one of the proposed questions of law. In fact, the proposed question of law is that whether the Tribunal erred in deleting the addition of Rs.10,57,01,194.00 made by the Assessing Officer under Sec. 2(22)(e) of the Income Tax Act, 1961 ('the Act') in contravention of the law laid down by the Supreme Court in the case of Vikram Krishna Vs. PCIT (2020), 114 taxmann.com 197 (SC).