(Per : HONOURABLE MR.JUSTICE V. M. SAHAI)
1. Heard Mr.S.N.Divetia, learned counsel appearing for the appellant and Ms.Mauna M.Bhatt, learned counsel appearing for the respondent.
2. Admit.
We formulate the substantial questions of law as under:
A. Whether on the facts and in the circumstances of the case, the Appellate Tribunal was right in law in holding that the burden lie on the appellant to prove that no satisfaction was recorded before the issuance of notice under section 158BD read with section 158BC of the Income Tax Act, 1961 and thereby rejecting the ground of appeal relating to the validity of block assessment ?
2. Whether on the facts and in the circumstances of the case as well as in law, the Income Tax Appellate Tribunal was justified in upholding the addition of Rs.12,94,875/- as unexplained investment towards purchase of land bearing No.776 and 777 in A.Y.1997-98 by the appellant ?
3. Paper book be filed within three months.
(V.M.SAHAI,J) (N.V.ANJARIA,J) ***vcdarji Top