TaxTMI 
TaxTMI 
2021 (10) TMI 914
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.... a question of law and was based on the material available on records? 2. That on facts and circumstances of the case and in law the reassessment proceedings were initiated on suspicion only, therefore whole of the reassessment proceedings are liable to be quashed. 3. That the assessment order is void and invalid in law as there is no escapement of income based on the original reasons recorded by the A.O. for reopening of case u/s. 148 of "the Act". 4. That on the facts and circumstances of the case, the Ld. A.O. and the Ld. CIT(A) both have failed to appreciate that interest u/s. 234A can be charged up to the due date prescribed u/s. 139(4) of the Act not the date of Assessment order. 5. Without prejudice to the above grounds, whet....
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....ived 1/4th share against sale of land to M/s. Shree Buildtech. The Assessing Officer noted that the land sold by the assessee was within 6 kilo meters of nearest to Municipal Limit and as such was a capital assets. The Assessing officer further observed that the cost of acquisition of the land as on 1/4/1981 was Rs. 27,000 per acre which was rate of similar land of nearby area during 1981-82. The Assessing Officer also obtaining information from Halka Patwari that the land was approximately two kilo meter away from the Municipal Limit of Gurgaon. The assessee contended that the said land was at a distance of 15 kilo meter from the Tehsil Sohna and as such was not a capital asset. The Assessing Officer considered the assessee's submissio....
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....ew/different address given in Form No. 36, hence we are proceeding on the basis of the submission made by the assesses before the Assessing Officer and before the CIT(A). 6. The Ld. DR relied upon the assessment order and the order of the CIT(A). The Ld. DR further submitted that the CIT(A) has taken proper cognizance and have given a partial relief as per law. 7. We have heard Ld. DR and perused all the relevant materials available on record. It is pertinent to note that the assessee has claimed deduction u/s. 54F of the Act on account of purchase of residential house for an amount of Rs. 18,00,000/-. There was a cash deposit in the bank account. It was only while examining the bank account that the issue of credit entry amounting to mor....