(1.) THIS is an appeal against the order of the Income Tax Appellate Tribunal, Amritsar (for short, the 'Tribunal') dated 27.03.2014 (Annexure A -7), upholding the decision of the Commissioner of Income Tax (Appeals) (for short, the 'CIT'), which in turn, computed the balance of the long term capital gains in respect of the land sold by the appellant at Rs. 55,93,517/ -. The matter pertains to the assessment year 2006 -07.
(2.) A search was conducted at the premises of one Rajan Setia. The documents seized at the search reflected transactions between the said Mr.Setia and one Y.Lali, who in turn, had purchased various pieces of land inter alia from the appellant's brother. The documents seized indicated that the lands were sold at a rate of about Rs. 19,837/ - per marla. In the re -assessment proceedings, it is this rate which has been applied in the case of the appellant's transactions.
(3.) THE appeal is admitted on the following substantial questions of law: