Hyfun Frozen Foods P. Ltd. v. ITO (2024)110 ITR 37 (SN) (Ahd) (Trib)

S. 69 :Unexplained investments-Land purchased in earlier year-Delayed payment-Registered sale without making payment to vendor-Addition cannot be made as undisclosed income.

Held that  the land  was purchased earlier through the sale deed and payment therefor was made subsequently. There were several justifiable factors for the delayed payment against the purchase of land. No document was brought on record by the Department suggesting that the assessee had incurred the expenses in connection with the purchase of land in cash so as to apply the provisions of section 69 of the Income-tax Act, 1961. Merely because the assessee got the property transferred through registered sale without making payment to the vendor, the provisions of section 69 of the Act would not be attracted.(AY.2015-16)

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