2019 (9) TMI 1415

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..... 2. Mr. G. Baskar & Mr. I. Dinesh represented on behalf of the Assessee and Mr. AR.V. Sreenivasan represented on behalf of the Revenue. 3. It was submitted by ld.AR that the assessee had purchased a property being a residential site at Sholingarnallur village, Tambaram Taluk, Kancheepuram district for a consideration of Rs. 1,44,00,000/- vide Sale Deed dated 11.09.2013. The assessment u/s.143(3) of the Act was completed on 29.12.2016 wherein addition of Rs. 7,40,000/- towards the source of purchase of the said property had been disbelieved and added back to the total income of assessee. It was a submission that the assessment was completed on 29.12.2016. Subsequently, a show cause notice u/s.263 of the Act came to be issued on 28.08.2018....

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....lue of the property purchased came to only Rs. 1,28,64,000/-. It was submitted that the PCIT did not accept the contentions of the assessee and applying the provisions of section 56(2)(vii) of the Act, ld.PCIT directed the Assessing Officer to assess the differential amount of Rs. 24,00,000/- and pass a fresh assessment order. It was a submission that the fact that the Tamil Nadu Government had reduced the rates itself showed that the guideline value as prescribed in 2012 with effect from 01.04.2012 by the State Government was excessive. It was a prayer that the addition as made by the PCIT be deleted. 4. In reply, the ld.DR vehemently supported the order of PCIT. It was a submission that the provisions of section 56(2)(vii) of the Act pro....