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Capital-gains liability under a development agreement requires factual verification where the sale deed and power of attorney indicate that the assessee acted only as the landowner's attorney holder. Because these documents were not produced before the lower authorities and required consideration alongside the Revenue's submissions, the liability was not decided on merits. The appellate order was set aside and the matter was remitted to the CIT(A) for fresh consideration of the documents and submissions.
Capital-gains liability under a development agreement requires factual verification where the sale deed and power of attorney indicate that the assessee acted only as the landowner's attorney holder. Because these documents were not produced before the lower authorities and required consideration alongside the Revenue's submissions, the liability was not decided on merits. The appellate order was set aside and the matter was remitted to the CIT(A) for fresh consideration of the documents and submissions.
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