2021 (5) TMI 895

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.... facts and circumstances of the case. 2. The learned CIT(A) has erred In condoning the delay in filing appeal by the assessee of 134 days without passing a speaking order. 3. The learned CIT(A) has erred to consider the fact that assessee himself had pleaded before the CIT(A) that the sale consideration of the impugned property as adopted by the DVO viz. Rs. 48.91 crores may be considered instead of value as per sec. 50C of the Act, as adopted by the Assessing Officer in the assessment order i.e. Rs. 100.04 crores. 4. The learned CIT(A) has erred in adopting the Sale consideration of the property as Rs. 52.66 crores instead of Rs. 32 crores as mentioned n the sale deed dt. 7/10/2011 because of which he wrongly con....

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....ed long term capital gain from sale of property at Rs. 2,62,02,032/- 4. Being aggrieved by the assessment order, the assessee preferred an appeal before the learned CIT(A). Before the learned CIT(A), the assessee has filed certain additional evidences and same has been forwarded to the Assessing Officer for his comments. The Assessing Officer vide his remand report dated 14.03.2018 submitted that although guideline value of property was fixed at Rs. 100.04 crores, but DVO vide his report dated 02.11.2017 has estimated the market value of the property as on the date of sale at Rs. 48.99 crores, which is more than sale consideration mentioned in registered sale deed. The learned CIT(A), after considering relevant submissions of the assesse....