Section 264 revision on capital gains deductions failed where no legal evidence supported brokerage and improvement claims.

Interference under section 264 of the Income-tax Act was declined in relation to disallowance of brokerage, eviction charges and cost of improvements claimed while computing capital gains. The revisional authority held that no relevant material amounting to legal evidence supported the claimed deductions and therefore refused to disturb the assessment order. In the writ petitions, the petitioners did not produce material to dislodge those findings, so no ground for judicial interference was made out and the challenge to the revisional orders failed.

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Issues: Whether interference was warranted under section 264 of the Income-tax Act, 1961 in relation to the disallowance of brokerage, eviction charges and cost of improvements claimed in computing capital gains.

Analysis: The petitioners had sold immovable property and claimed deduction of expenditure towards brokerage, eviction charges and cost of improvements. The revisional authority found that there was no relevant material constituting legal evidence to support those claims and declined to interfere with the assessment order. In the writ petitions, no material was pointed out to dislodge those findings.

Conclusion: No ground for interference was made out, and the challenge to the revisional orders failed.

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