2025 (10) TMI 312

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....wal i/b Mr. Rajesh Poojari Mini and Confreres,. P.C.:- 1. Heard Mr. Ranganayakulu, learned counsel for the appellant and Mr. Madhur Agarwal appears with Mr. Rajesh Poojari, for the respondent. 2. Mr. Ranganayakulu proposes the following questions, which according to him, are substantial questions of law: "A. Whether on the facts and in the circumstances of the case and in law, th....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....lar flats located in the same building as much as Rs. 34,926/- per sq. ft. sold to Ara Corporate Consultants Pvt. Ltd. and Rs. 35,618/- per sq. ft. sold to Annapanna Software Memorial Building as against Rs. 62,893/- per sq. ft. sold to Trap Consultants P. Ltd., is a colorable device adopted by the assessee to evade the tax. C. "Whether on the facts and in the circumstances of the case an....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ed with a factual dispute and raises no question of law, much less any substantial question of law. 4. Regarding the other questions, we note that they are similar and relate to the issue of three comparable flats on the same floor being sold at different rates. Mr. Ranganayakulu stated that two of the flats were sold at Rs. 34,926 and Rs. 35,618 per sq. ft. However, the third flat on the same ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....finding that has not been seriously disputed. He submitted that in such circumstances, the sale of the third flats for a substantially higher rate cannot lead to any inference of a cash transaction. In any event, he submitted that such a factual determination gives rise to no question of law. 6. We have considered the rival contentions and are satisfied that even questions two and three do not ....