Court : Income Tax Appellate Tribunal ITAT Panji
Reported in : (2003)87ITD1Panji
1. Since common issues are involved in all these appeals, the same are consolidated and disposed of by a single order for the sake of convenience. The assessees at Sr. Nos. 3 and 4 are the spouses of Mr.Dominic Dias and Mr. Richard Dias respectively and all the assessees are governed by the Portuguese Civil Code.2. The first common grievance of the assessee is that the learned CIT(A) is not justified in holding that the proceedings under Section 147 of the Act were properly initiated with sufficient ground for issue of notice under Section 148. All the four assessees are co-owners of agricultural land measuring 1,08,000 sq. mtrs. situated at Canacona.The said land was sold to M/s Deeksha Holding Co. (P) Ltd. who purchased the same on 27th Oct., 1994, for a consideration of Rs. 1,69,56,000 for construction of a beach resort. The share of each assessee being Rs. 42,39,000.3. The assessees had filed returns of income for asst, yr. 1995-96 on 31st Oct., 1995, which were processed under Se...
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