1991 (3) TMI 78

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....-Heard counsel for the petitioner and learned counsel for the Revenue. This writ petition is directed against an order of the Commissioner of Income-tax, under section 264 of the Income-tax Act, 1961, dismissing the revision petition filed by the petitioner-assessee. The assessment year concerned is 1984-85. During the previous year relevant to the said assessment year, the assessee purchased a....

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....e the sale deed mentions the value of the property at Rs. 2,07,500 for the purposes of stamp duty and stamp duty was paid thereon and also because the assessee has not produced any documentary evidence to support his case, there are no grounds for interference. The assessee did not Me an appeal to the Tribunal against the order of the Appellate Assistant Commissioner. He chose to Me a revision und....

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....to the facts and circumstances of that case. In this case, the petitioner brought to the notice of the Commissioner that the portion purchased by him was under the tenancy of his mother and actually they were themselves occupying it. This may be a reason for selling the house at a rate lesser than fair market value or it may not be ; but that is question of fact. It is true that the Income-tax Off....