JATIA INVESTMENT CO Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) In this reference under Section 256(1) of the Income-tax Act, 1961, the following questions of law have been referred to this court for the assessment year 1976-77 : "1. Whether, on the facts and in the circumstances of the case, the Tribunal's findings that the assessee had paid cash for purchase of shares and that it was not able to show how it was provided and that the concern from whom loan was taken did (not) have enough to lend the assessee are perverse and based on no materials and/or were arrived at by ignoring relevant materials ?

(2.) Whether, on the facts and in the circumstances of the case, the finding of the Tribunal that the Income-tax Officer was justified in drawing the conclusion that the assessee brought cash into the books of account for the purchase of shares but the source thereof was unexplained is vitiated being perverse and/or having been arrived at on a consideration of irrelevant materials and/or by ignoring relevant materials ?

(3.) Whether the order of the Tribunal upholding the addition of Rs. 11,20,000 as the assessee's income from undisclosed sources is vitiated on account of non-consideration of the various contentions advanced on behalf of the assessee and is perverse ?