Dismissing the appeal of the revenue the Court held that , the findings returned by the Tribunal in respect of the five deletions made by the AO exhibited due application of mind on the part of the Tribunal and on the basis of the factual evidence on record. There was no perversity or ambiguity, in the findings returned by the Tribunal. The CIT (A) had dealt with the related issues in great detail and his findings had been affirmed by the Tribunal. There was no reason to believe that the findings recorded were incorrect or improper. No question of law .( BP 1-4-1988 to 13-2-1999)
PCIT v. Sunil M. Thakkar (2020) 426 ITR 372/ 195 DTR 64 / 317 CTR 262 (Bom)(HC)
S. 158BC : Block assessment – Search And Seizure —Undisclosed Income —Deletion of addition based on facts – No perversity or ambiguity – No substantial question of law [ S.132 , 133A 153C ,158BB 158BC ]