2007 (7) TMI 240

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....t of the credits shown from various parties despite the non-satisfaction of the conditions laid down under section 68 of the Income-tax Act by the assessee in respect of the credits ? 2. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was legally correct in deleting the addition of Rs. 3,83,000 for the assessment year 1986-87 in respect of the credits shown from various parties despite the non-satisfaction of the conditions laid down under section 68 of the Income-tax Act by the assessee in respect of the credits ? 3. Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal was legally correct in deleting the addition of Rs. 43,543 for the assessment year 1....

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....s and entities including the funds of the HUF and also Shri Lalit Kumar Goel, individual. It is a matter of record that the Income-tax Officer referred the matter to the Valuation Officer for purposes of determining the investment in the house property and the said Valuation Officer vide his report dated March 16, 1991, estimated the same at Rs. 81,64,000. The Income-tax Officer further expressed dissatisfaction with the replies and explanations given about the sources of the funds from which the property had been constructed. He also highlighted another aspect of the matter and that being the claim made by the different individuals from whom the assessee purported to have received the funds ; that the amounts withdrawn by them had been uti....

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....ed opinion that the finding recorded by the Tribunal, which is to the following effect, is based on evidence and material available on record : "We are wholly in agreement with the views expressed by the Commissioner of Income-tax (Appeals) and these having been arrived at after considering the submissions of the assessee's counsel with reference to the evidence and material available on record and also considering the submissions of the Income-tax Officer who was present during the appeal proceedings. We need only refer to one particular aspect and that being the finding of the Income-tax Officer in the assessment order to the effect that the withdrawals made from different sources 'might have been utilised for purposes of meeting househo....