1 IN THE HIGH COURT OF JUDICATURE AT BOMBAY ORDINARY ORIGINAL CIVIL JURISDICTION INCOME TAX APPEAL NO.1156 OF 2007 The Commissioner of Income Tax ..Appellant. V/s. Shri Mahavir C. Ranka ..Respondent. AND INCOME TAX APPEAL NO.1157 OF 2007 The Commissioner of Income Tax ..Appellant. V/s. Shri Jayantilal C. Ranka ..Respondent. AND INCOME TAX APPEAL NO.1159 OF 2007 The Commissioner of Income Tax ..Appellant. V/s. Shri Bakhtawar C. Ranka ..Respondent. Mr. D.M.Kamwal for appellant. Mr. A.K. Jasani for respondent. CORAM : V.C.DAGA AND J.P.DEVADHAR, JJ. DATED : 14TH AUGUST, 2009. P.C. :- 1. Heard learned counsel for the revenue. The issue sought to be raised in the above appeals revolve around he appreciation of evidence. The Tribunal has rightly come to the conclusion that if the assessing officer wants to tax the value of the assets noted in the seized paper, he must necessarily allow the deduction for liabilities which are noted on the very same paper. 2 The Tribunal has held that the judgment of the Allahabad High Court in the case Dr. S.C. Gupta V/s. CIT [248 ITR 782 (All)] is distinguishable on the facts as in the present case, the assessee had discharged the burden. The Tribunal appears to have accepted the finding recorded by CIT. The view taken by the Tribunal appears to be reasonable and possible view. In this view of the matter, no substantial question of law is involved in the appeal. The appeal is dismissed in limini with no order as to costs. (J.P.DEVADHAR, J.) (V.C.DAGA, J.)