ITA 80 of 2009 1 IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH. ITA No.80 of 2009 Date of decision 2.2.2010 The Commissioner of Income Tax ... Appellant Versus Shri Rajesh Kumar Bansal ... Respondent CORAM: HON'BLE MR. JUSTICE M.M. KUMAR HON'BLE MR. JUSTICE AJAY TEWARI Present: Ms. Urvashi Dhugga ,Advocate for the appellant 1.To be referred to the Reporter or not ? 2.Whether the judgement should be reported in the Digest ? M.M.KUMAR, J. This order shall dispose of two appeals being ITA Nos. 80 and 81 of 2009 as by a common order dated 31.7.2008 passed by the Income Tax Appellate Tribunal, Chandigarh Bench, Chandigarh both the appeals were disposed of namely, ITA Nos. 940 and 941/Chandi of 2006 pertaining to the assessment year 2000-01. The issue is identical which involve two godowns built by two brothers. The Assessing Officer placed reliance on the Valuation report which was presented for the purposes of obtaining loan from the Bank.According to Tribunal the CIT (A) erred in law in holding that there was no material on record to justify the higher cost of construction. The explanation furnished by the assessee was found reasonable. It was also found that the revenue did not bring anything on record suggesting that expenses incurred were more than the one declared and the Valuation report alone cannot constitute basis for making additions. Having heard the learned counsel we find that these are pure ITA 80 of 2009 2 findings of fact and would not give rise to a question of law much less a substantive question of law. The appeals do not warrant admission and consequently the same are dismissed. A copy of this order be placed on the file of connected case. (M.M.Kumar) Judge (Ajay Tewari) 2.2.2010 Judge okg