TaxTMI 
TaxTMI 
2009 (10) TMI 291
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....R GOEL J.- This appeal has been preferred by the Revenue under section 260A of the Income-tax Act, 1961 (in short, "the Act") against the order dated February 4, 2009, passed by the Income-tax Appellate Tribunal, Delhi Bench "F", New Delhi, in I. T. A. No. 2993/Del/2008, for the assessment year 1993-94, proposing to raise the following substantial question of law: "Whether on the facts and in the....
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....ceived towards consideration for sale of material, was not accepted. Inference was drawn that the assessee siphoned off its unaccounted money by making M/s. Sahib Engineering Works a conduit pipe through which unaccounted money travelled and reached back to the assessee. Thus, addition was made to the declared income. Further additions were made by holding that lease rent shown to have been paid b....
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....the findings of the Tribunal that transaction for sale, for which amount is alleged to have been received from M/s Sahib Engineering Works, was genuine, is perverse. 6. This contention cannot be accepted. The Tribunal has recorded reasons taking into account, inter alia, the following circumstances: "A. The assessee sold steel to MIs Sahib Engineering Works. B. M/s. Sahib Engineering Works have....
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....orks and money which came into the account of M/s Sahib Engineering Works came from accounts of M/s. Kotak, SRF and Times. Thus, the assessee has not only proved source of its credit but also proved source of source with corroborat ing overwhelming evidence." 7. The above reasons cannot be held to be non-existent. The matter is in the realm of appreciation of evidence. Even if it is held that two....