TaxTMI 
TaxTMI 
2021 (5) TMI 966
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....e learned CIT(A) erred in deleting the addition of Rs. 1,87,32,500/- made by the Assessing Officer. 3. In the facts and circumstances of the case, the Ld. CIT(A) erred in allowing the appeal when the assesses failed to explain how he received and utilized the sale consideration of a land for which he is not the title holder. 4. The Ld. CIT(A) erred in allowing the appeal without considering the fact that the land was not agricultural land at the time of sale and no agricultural activities were carried out at the time of sale. 5. Any other ground(s) that may be urged at the time of hearing. 2. Briefly the facts of the case are that the assessee filed his return of income for the AY 2013-14 declaring a total income of Rs. 12,14,090/- o....
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.... of the property could not establish the source of investment made by him and the transaction of sale agreement executed on 23rd July, 2012 was not canceled and he has received payment as per the sale deed. He submitted that the agreement was made on 13/03/2012 between K. Vijayasri and Bukka Kanakaiah and others and they have developed the land by way of plotting. He submitted that as per the revenue record, the land was dry land and it is the duty of the assessee to get it changed on revenue documents, if the assessee is utilizing the land other than as mentioned in the revenue record. He contended that the CIT(A) has wrongly deleted the addition made by the AO without considering the findings and documents found during the course of searc....
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....ide Doc No. 2009/2001 executed on 16.05.2001 between Sala Sailu and K. Vijayasri along with English Translations. CIT(A) & AO 60-70 10. Sale Agreement for Agriculture Land executed on 13th March 2012 between K. Vijayasri and Sukkjl Kanakaiah. CIT(A) & AO 71-76 11. Cancellation agreement executed on 25th June 2012 between Smt K. Vijayasri and V.V. Rajam CIT(A) & AO 77-79 12. Sale Agreement executed on 23rd July 2012 between K. Vijayasri and V.V. Rajam. CIT(A) & AO 80-84 13. General Power of Attorney Given by Smt. Vijayasri to V.V. Rajam along with proof of identity. CIT(A) & AO 85-90 14. Sale Deed executed on 02nd Aug 2012 vide Doc No. 6876/2012 between Vijayasree and B.Mallareddy along with English Transl....
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....ubaga Vijaya Sri (represented by her GPA Sri VV Rajam), Vendor in favour of Bussa Malla Reddy, Didigam Satyanarayana, Koda Ashok and Chirlencha Satyaranara at a sale price of Rs. 62,00,116/ per acre and advance was received for an amount of Rs. 1,12,50,000/-. Further, the GPA holder, i.e. assessee has entered into an agreement for sale of the aforesaid property on 02/08/2012 with Bussa Mallareddy, P. Anil & Bada Ashok for a consideration of Rs. 12,67,500/- for the entire aforesaid property as tabulated (infra) in para 11 of the assessment order. 8.1 On going through the documents submitted by the assessee before us, the assessee had received payment as per the sale deed dated 23rd July, 2012 has not been cancelled and again the said proper....
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....nnala village was sold? If sold give the details of purchasers. Ans: Yes. The land was sold to following persons: Sl.No. Name Document No. Area Sale consideration (Rs.) 1 Bada Ashok 6474/2012 dt. 02/08/2012 1 ac. 9 gts. 3,67,500 2 P. Anil 6875/2012, dt. 02/08/2012 2 Ac 6,00,000 3 Bussa Malla Reddy 6876/2012, dt. 02/08/2012 O ac 9 gts. 67,500 4 Bussa Malla Reddy 6877/2012, dt. 02/08/2012 31 9 gts. 2,32,500 12. How come the property which was agreed to sell for at Rs. 2.48 crores was sold at a meagre value Rs. 12,67,500/-? Ans: The rate mentioned above is in accordance with the registration document which was ordered by the Dy. Inspector General, registration and stamps, Nizamabad, though I re....
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....essee during the course of search proceedings at question & answer No. 15. Therefore, we are of the view that the AO has rightly made the addition for unaccounted cash. The assessee has submitted before the CIT(A) wrong facts that in the particular land there was a well and bore-well, but, on perusal of the sale deed executed on 02/08/2012, nowhere it has been mentioned under the 'Declaration' that there is a well or bore-well, which is clear from the page No. 69 of the translated sale deed at pages 102, 119 and 138. When the property was purchased in 2001 was a dry agricultural land, but, subsequently, when sale was materialized on 02/08/2012, nowhere it is mentioned in the translated document that the land was agricultural land. Before th....