Tax Authorities' Forfeiture Claim Lacks Evidence; Section 51 of Income Tax Act Reduces Property Cost Due to Forfeiture.

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....Addition u/s. 28(iv) - advance money against sale of property forfeited by the assessee - Merely for the reason that the amount received as loan in an earlier year was converted into advance payment for purchase of property, there is no reason to disbelieve the property transaction as a colourable device. No material has been brought to substantiate the above said view of the tax authorities, meaning thereby, they have entertained this view only on surmises and conjectures. - the provisions of section 51 of the Act shall be applicable and the above said amount would go to reduce the cost of property. - AT....