1993 (12) TMI 98

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....ent dt. 27th Sept., 1983 entered into with M/s Peirce Leslie (India) Ltd., the vendor agreed to sell 466 cents of land with buildings thereon at Calicut either to the appellant or to its nominees. As per the agreement, if the purchase price was not paid within the specified time, the appellant was to pay interest at 18% per annum. The buildings on the lands purchased were demolished and the scrap ....

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....art of interest referable to the lands sold to the sister concerns cannot be allowed as revenue expenditure. He allowed only the interest referable to 65.57 cents of land retained by the assessee. Thus, he gave part relief. The assessee is on further appeal. 3. We have heard rival submissions. The assessee had furnished the particulars of property agreed to be purchased from Peirce Leslie Co. L....

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....avour of Kerala Roadlines. 12. Sale deed dt. 21st Dec., 1985 in favour of Kerala Roadlines. 13. Sale deed dt. 29th Dec., 1986 in favour of Kerala Roadlines. In addition, the agreement dt. 27th Sept., 1983 with Peirce Leslie Co. Ltd. has also been furnished. We have perused the documents. The agreement for sale of 466 cents of land with buildings thereon is between M/s Peirce Leslie Co. Lt....

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....T(A) would be right in his view if the assessee had acted only as an intermediary in the transactions between the vendor and sister concerns, who have ultimately purchased 399.43 cents of land out of the total of 466 cents of land agreed to be purchased by the assessee or its nominees under the agreement dt. 27th Sept., 1983 with the vendor. But the assessee in this case did not content to remain ....