2019 (8) TMI 468

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....d an order dated 12.3.2019 passed by the Commissioner of Income Tax dismissing the petitioner's revision petition under Section 264 of the Income Tax Act, 1961 ("the Act" for short). 2. At the outset, learned counsel for the petitioner stated that the petitioner had also filed Income Tax Appeal against the same order of assessment, however, the same was subsequently withdrawn. 3. Brief facts are....

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....t on 26.12.2017 ex-parte and held that the petitioner had total income of Rs. 67,60,000/- during the said year. In the order of assessment, he has recorded that the petitioner had purchased two immovable properties for a total consideration of Rs. 66 Lakhs, the source of which was not disclosed. 5. The petitioner filed Revision Petition before the Commissioner in which she first sought to explain....

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.... had purchased another immovable property in the nature of flat on 3.8.2009 for total consideration of Rs. 36 Lakhs, again her share being 50% thereof, the remaining 50% having come from her husband. Along with Revision Petition, she also tried to file a return explaining these details further. 6. The Commissioner, by the impugned order, heard Revision Petition only on the ground that the assesse....

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.... Nevertheless, it would not be difficult for the Commissioner to do so while re-examining her Revision Petition. He could either call for a remand report and decide this issue himself or remand the proceedings before the Assessing Officer for fresh assessment. 8. The petitioner's representation that she had never purchased two properties as suggested by the Assessing Officer needs further exa....