Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
HC upheld lower authorities' concurrent findings that share transactions were a colourable device to avoid tax. The court determined this was a factual conclusion supported by evidence rather than a substantial question of law requiring intervention. The assessee's belated argument about potential loan deductions was dismissed as hypothetical. The court emphasized its limited scope to interfere with factual findings when backed by material evidence. Given the consistent determinations by three authorities and adequate supporting documentation, the court found no grounds to disturb the established position that the transactions constituted tax avoidance. Appeal dismissed.
HC upheld lower authorities' concurrent findings that share transactions were a colourable device to avoid tax. The court determined this was a factual conclusion supported by evidence rather than a substantial question of law requiring intervention. The assessee's belated argument about potential loan deductions was dismissed as hypothetical. The court emphasized its limited scope to interfere with factual findings when backed by material evidence. Given the consistent determinations by three authorities and adequate supporting documentation, the court found no grounds to disturb the established position that the transactions constituted tax avoidance. Appeal dismissed.
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