2014 (2) TMI 1428

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....re heard together and are being disposed of by this consolidated order for the sake of convenience. 2. The assessee has raised identical grounds in all the appeals. The grounds raised in ITA No.352(Asr)/2009 which are identical in other two appeals except variation in amounts, are reproduced, for the sake of convenience, as under: "1. That the Ld. CIT(A) misdirected himself in law and facts, in upholding the assumption of jurisdiction by the ITO by invoking the provisions of section 147/148. 2. That the Ld. CIT(A) was justified in upholding the action of the ITO in declining the assessee's claim that the impugned transactions of purchase and sale of agriculture land were in HUF capacity and that the same were therefore,....

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....e, moreso, when cross examination of persons making such statements was not allowed. 9. That even otherwise, in the light of mutually conflicting and contradictory statements of the seller, the buyer and the witnesses, made at different stages, the addition of alleged payment of 'on-money' beyond the registered sale deeds, ought to have been deleted by the CIT(A) relying upon the Apex Court decision (2007) 294 ITR 49 (SC) 10. That charging of interest u/s 234A and 234B has been wrongly upheld. 11. That the impugned order is wholly against law and facts of the case." 3. The facts as narrated by the revenue authorities are not disputed by both the parties, therefore, there is no need to repeat the same for the sa....