TaxTMI 
TaxTMI 
2026 (7) TMI 1328
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....ppellant - Revenue has proposed the following substantial questions of law arising out of the order dated 28.02.2020 passed by the Income Tax Appellate Tribunal, Rajkot Bench, Rajkot (for short "the Tribunal"), in ITA No. 137/Rjt/2016 for the Assessment Year 2012-13: "[A] "Whether on the facts and in the circumstances of the case, the Appellate Tribunal is justified in deleting the addition of Rs. 10,20,62,695/- made under Section 69C of the Act on the basis of jantri rate issued by the Superintendent of Stamps?" [B] "Whether on the facts and in the circumstances of the case, the Appellate Tribunal is justified in upholding the decision of the CIT(A) deleting disallowance of deduction of Rs. 6,82,21,445/- claimed under Sec....
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....ioner of Income Tax (Appeals). The Commissioner of Income Tax (Appeals), vide order dated 25.02.2016, allowed the appeal on all the grounds raised by the assessee and deleted the aforesaid additions made by the Assessing Officer. 3.4 Being aggrieved by the order passed by the Commissioner of Income Tax (Appeals), the revenue preferred an appeal before the Tribunal. The Tribunal dismissed the appeal of the revenue after upholding all the grounds raised by the assessee before the Commissioner of Income Tax (Appeals). 3.5 Being aggrieved by the order passed by the Tribunal, the present tax appeal is preferred by the Revenue. 4. Having gone through the facts of the case, the Tribunal has dismissed the appeal preferred by the revenue. T....
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....ificate was issued for part completion of the project dated 15th of December 2011 and the final certificate for the completion of the project was issued dated 22 March 2012. Thus from the final certificate issued by the competent authority for the completion of the entire project, it is established that there was the no violation of the provisions of law as specified under the provisions of section 80IB(10) of the Act. At the time of hearing, the learned DR has not brought anything on record contrary to the finding of the learned CIT (A). Hence we do not find any reason to interfere in the order of the learned CIT (A). Thus the ground of appeal of the Revenue is dismissed. 12. The last issue raised by the revenue is that the learne....
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....s categorically observed that there is no iota of evidence available before the Assessing Officer suggesting that the assessee had incurred any expense which were not disclosed in the books of accounts. It was further observed by the Tribunal that during the survey operation, there were no details qua the assessee suggesting that the expenses were incurred by the assessee outside the books of accounts. Further, with regard to the issue of Section 80IB(10) of the Act, the Tribunal has categorically observed that from perusal of the final certificate issued by the competent authority, it is pertinent to note that there was no violation of the provision of law as provided under Section 80IB(10) of the Act. It was further observed by the Tribun....