2019 (7) TMI 599

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....e ld.CIT(A)-4, Ahmedabad of even dated i.e. 18.1.2017 in the cases of the above four assessees. On receipt of notice on the appeals of the Revenue, assessee have also filed respective cross objections as numbered in the cause title. Since in all these appeals and COs common issue is involved, all of them are disposed of by this single order. 2. Grounds raised by the Revenue in all these appeals are identically worded except variation in quantum of penalty. Sole grievance of the Revenue in these appeals is that the ld.CIT(A) has erred in deleting penalty imposed by the AO under section 271(1)(c) of the Income Tax Act. The quantum of penalty imposed by the AO and deleted by the CIT(A) qua each assessee is as under: i) M/s.Maitrik ....

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....n that the assessee-group has received Rs. 15.07 crores as discussed above as on-money from sale of land in question from CCPL. As discussed above, in the case of Dr. Keyur Parikh and others in IT(SS)A Nos. 604/Ahd/2011, it has been held by the ITAT that there was no evidence in possession of Revenue:; to hold that the assessee made unexplained investments towards the purchase of land in question. Nothing contrary was brought to our knowledge on behalf of the Revenue. Since the assessee is a recipient in respect of the same property and it has been held by ITAT that in case of purchaser no unexplained investment has been made in respect of said property as discussed above. So, the addition on receiving on-money in question in the hands of t....