2026 (7) TMI 880

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

..... Mamta Singh, Sr. DR ORDER PER DR. B.R.R. KUMAR, VICE-PRESIDENT:- This appeal is filed by the Assessee against the appellate order dated 16.03.2026 passed by the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre, Delhi, relating to the Assessment Year 2014-15. 2. The assessee has raised the following grounds of appeal: The appellant prefers the present appe....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ing on record any direct evidence proving that the appellant has actually paid cash of Rs 26,57,000/- Mere entries in third-party records cannot be treated as conclusive evidence. 4. Incorrect invocation of Section 68 The addition u/s 68 is legally untenable as: There is no credit entry in the books of appellant, The alleged transaction pertains to inve....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ry and excessive addition The addition sustained by CIT(A) is excessive, arbitrary and not supported by evidence or law 8. Right to add, amend grounds The appellant craves leave to add, alter or amend any grounds of appeal at the time of hearing. 3. The undisputed facts emerging from the record are that Industrial Shed No. 55 situated at Kushal Industrial Park, Survey....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e lower authorities clearly establish the actual contribution made by each of the co-owners towards the recorded purchase consideration. The details are as under: Name Amount Paid (Rs.) Share Deepak Shankarlal Patel (Assessee) 2,34,000 17% Shankarlal Dahyabhai Patel 8,00,000 58% Mitul Patel 3,41,000 25% Total 13,75,000 100% 5. In our considered view,....