PCIT v. Ghanshyam Dungarbhai Sutaria (2020) 425 ITR 601 (Guj)(HC)

S.143(3) : Assessment- Survey- Telescoping and reducing the addition – Income from undisclosed sources — Additions deleted by Tribunal on facts — No substantial question of law .[ S. 133A, 260A, 292C ]

Dismissing the appeal of the revenue the Court held that   that the question raised by the Revenue could not be termed a substantial question of law as the Tribunal had considered the effect of the provisions of S.  292C as applied by the CIT (A ) by telescoping and reducing the addition giving partial relief to the assessee. As regards   deleting the other addition, the Tribunal on the basis of the materials produced before it and after analysing them had arrived at a finding of fact. No interference was warranted. As there were concurrent findings of fact by both the authorities, none of the other deletions could be questioned.( AY.2009-10)