2022 (6) TMI 83

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....2021 in the IT (SS) A No.121/Ahd/2018 for the A.Y. 2011-12. By way of Tax Appeal No. 176 of 2022, the Revenue has challenged the order dated 29.09.2021 passed by the Income Tax Appellate Tribunal, "A" Bench, Ahmedabad in C.O. No.110/Ahd/2019 for A.Y.2011-12. 2. The Revenue has proposed the following questions for consideration of this Court in both the Appeals: Tax Appeal No.174 of 2022: [A] "Whether on the facts and circumstances of the case and in law, the Appellate Tribunal has erred in upholding the decision of the CIT(A) deleting the addition of Rs.2,89,83,750/- without appreciating the fact that the assessee himself admitted involvement in land transactions and provided the information related to the land sold at Zundal....

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....y the documentary evidences but the assessee never provided the details of the partners and merely filed the retraction affidavit without any supporting or cogent evidences?" [E] "Whether the Appellate Tribunal has failed to appreciate the fact that the assessee remained non compliant during the post search proceedings and filed retraction affidavit almost after 6 months which cannot be accepted as the assessee voluntarily admitted the receipt of Rs.3 crores as commission in the statement recorded u/s.131 of the Act on 13.06.2013?" [F] "Whether the Appellate Tribunal has failed to appreciate the fact that the assessee filed the retraction affidavit after a long gap of 6 months without any corroborative evidences even when ....