2011 (5) TMI 570

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..... (Oral)   1. A search and seizure operation was carried out on 22nd September, 2005 under Section 132 of the Income Tax Act, 1961 at the premises of Sh. Pravin Juneja at E-47, Greater Kailash-II, New Delhi and during the course of said search documents relating to sale and purchase of property were found. In those documents transaction had been carried out in the name of his wife Smt. Bel....

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.... an agreement dated 20th October, 2004 executed between Sh. A.B. Singh, owner, and Sh. Pravin Juneja for the purchase of the said property was found. As per this agreement, the property was agreed to be sold for consideration of Rs. 31 lakhs by Sh. A.B. Singh on 20th October, 2004. An amount of Rs. 1 lakh was shown to have been received by the vendor in cash and Rs. 15 lakhs was paid on 25th Octob....

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....t has not adduced any cogent evidence to suggest the reasons for reduction in the purchase price from Rs.31 lakhs as agreed vide agreement dated 24-10-2004 to Rs.8 lacs shown in the deed registered on 29-10-2004. By considering the surrounding circumstances and also applying the test of human probability, it is clear that the appellant had paid a total consideration of Rs.31 lacs, whereas the sale....

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.... "Coming to the material available on record, enough evidence was found by the lower authorities pertaining to assessee from the premises in which she was living that the above payment in respect of property was made by her. The same has neither been accounted for nor assessee has given any satisfactory reply about the investment in question. In view thereof, we see no infirmity in the orders of....