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ITAT set aside additions made under s.56(2)(x)(b) regarding alleged undervaluation of immovable properties purchased below stamp duty value. The Tribunal found both lower authorities passed non-speaking orders without addressing assessee's submissions or providing reasoned findings. CIT(A)'s order demonstrated lack of application of mind, seeking reasons for delayed registration without previously requesting such information from assessee. The rejection of assessee's explanation and invocation of s.56(2)(x) lacked substantive reasoning, violating principles of natural justice under audi alteram partem. Matter remanded to AO for fresh consideration with proper opportunity for assessee to present case.
ITAT set aside additions made under s.56(2)(x)(b) regarding alleged undervaluation of immovable properties purchased below stamp duty value. The Tribunal found both lower authorities passed non-speaking orders without addressing assessee's submissions or providing reasoned findings. CIT(A)'s order demonstrated lack of application of mind, seeking reasons for delayed registration without previously requesting such information from assessee. The rejection of assessee's explanation and invocation of s.56(2)(x) lacked substantive reasoning, violating principles of natural justice under audi alteram partem. Matter remanded to AO for fresh consideration with proper opportunity for assessee to present case.
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