The ITAT held that the assessee failed to explain the nature and...

The ITAT held that the assessee failed to explain the nature and source of investment with necessary supporting evidence. The PCIT's action invoking section 263 was in accordance with statutory provisions. While the AO should have taxed Rs. 14,93,393/- u/s 56(2)(x) and Rs. 33,18,000/- u/s 69 instead of the entire stamp duty value, the matter was set aside to the PCIT for further inquiry regarding year of purchase, purchase cost, and date-wise payments to determine the amount of investment u/s 69. The assessee's appeal was partly allowed for statistical purposes.

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