COMMISSIONER OF INCOME TAX Vs. PARVESH MAHAJAN

JUDGEMENT

(1.) THE present appeal under Section 260 -A of the IncomeTax Act, 1961 (for short 'the Act') is directed against an orderpassed by the Income Tax Appellate Tribunal, Amritsar Bench,Amritsar (for short 'the Tribunal') on 11.04.2012 for theassessment year 2007 -08. The Revenue has claimed thefollowing substantial questions of law:

(2.) THE assessee filed her return of income declaringincome of Rs.1,44,840 on 17.03.2008. Vide order dated22.12.2009, the income was assessed at Rs.54,44,839/ -. The assessee filed an appeal before the learned Commissioner ofIncome Tax (Appeals). Learned Commissioner of Income Tax(Appeals) confirmed the addition of Rs.53 lacs made by the Assessing Officer on account of unexplained investment forpurchase of land from Radha Swami Satsang Beas, Karan Ban,Jammu. However, in further appeal, the Tribunal has deleted the addition as the assessee is said to have explained the sources forpurchase of land during the year in question.Learned Tribunal has found that a sum of Rs.52 lacs wasreceived from M/s SAR Stitchers Pvt. Ltd. Delhi on 05.01.2007.The Tribunal also noticed that Rs.60 lacs was paid in cash to Radha Swami Satsang Beas, Karan Ban, Jammu, which deposit findsmention in the accounts of seller. The Tribunal has taken intoconsideration the record produced by the assessee in respect of transaction entered with copy of confirmations, PAN number,Income tax particulars and audited accounts of the lendor. We find that the finding that the investment of Rs.52 lacs was duly explained by the assessee, is a finding of fact and suchfinding of fact does not give rise to any substantial question oflaw.