2015 (9) TMI 1652

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....y resides at Chandravatiganj, while his tax practitioner is at Ujjain and due to this fact and lack of knowledge about filing of appeal, he could not contact his tax practitioner. The assessee has, therefore, prayed for condonation of delay. On the other hand, the learned DR opposed the prayer of the assessee. 2. After considering the submissions of the assessee, we find it appropriated to condone the delay as it was attributable to ignorance of knowledge about filing of appeal and difficulty in contacting the tax practitioner who resides at a different place than that of the assessee. The delay is, therefore, condoned and the matter is heard. 3. The grounds of appeal taken by the assessee are as under:-- "1. That the order of Commissio....

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.... details of bank deposits in his name and in the names of family members. It was claimed before the Assessing Officer that the entire amount came from the sale of the land. The Assessing Officer also recorded this fact in his order which is reproduced as under:-- " The assessee is a registered medical practitioner (Ayurvedic Doctor) practicing at Village - Chandravatiganj. The assessee has sold agricultural land at village Patlod, The Sawer, Distt. Indore on 19.11.07. The registry cost of land is only Rs. 20,20,000/-. However, the assessee claims to have received a sum of Rs. 1.18 crores on sale of this land. The assessee has given details of bank deposits in the name of self and family members and claims that the same is entirely out of ....

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....greed to sell at Rs. 4,51,000/- per bigha. He has received cash of Rs. 1,50,000/- as advance on 6.10.2007 and cash of Rs. 55,50,000/- on 15.10.2007. The balance amount was to be received by 15.1.2008 and then assessee was bound to do registration in purchaser's name or in any person's name whom the purchaser wanted to get it registered. The assessee submitted this agreement before the Assessing Officer which he has duly apprised and accepted the contents as true to explain the transaction in the assessee's bank account as he has not made any addition to that effect. In such a situation, any contrary view taken by the CIT with regard to the contents of the agreement for sale of the land shall amount to change in the view on the s....