2015 (4) TMI 1174

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....Sharma, Advocate, for the respondent. **** S.J.Vazifdar, Acting Chief Justice (Oral): The appellant has raised the following questions of law: "(i) Whether on the facts and circumstances of the case, the Hon'ble ITAT was justified in law, in deleting the addition of Rs. 1,25,00,000/- made u/s 2(22)(e) of the Income Tax Act, 1961 which was partly confirmed by the CIT(A) to the tune of Rs. 2....

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....l, by the order of the Division Bench dated 20.02.2015.   3. The second question raised is not a substantial question of law. It is purely a question of fact. The Commissioner of Income Tax (Appeals) and the Income Tax Appellate Tribunal rightly held that the mere fact that the assessee obtained loans @ 12% per annum does not belie the assessee's contention that the loans are from the fa....