2014 (9) TMI 91

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....n the concurrent findings of fact in relation to the applicability of Section 2(47) clause (v) of the Income Tax Act, 1961. 2. Very few facts need to be noted and which are admitted. 3. An agreement for development dated 11th November 1999 is between the assessee and a builder and developer. The assessee has 10% undivided share, right, title and interest in a plot of land along with coowners. Sh....

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....d. A return of income was filed for this assessment year on 26th July 2001. That Commissioner of Income Tax equally the Tribunal while upholding the conclusion of the Assessing Officer held that the stand of the assessee herself is enough to denote that Section 2(47) (v) will be applicable. The findings of fact in paragraph nos.8 and 9 of the Tribunal's order reaffirms the position that Sectio....