TaxTMI 
TaxTMI 
2022 (6) TMI 877
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....) was filed for the assessment year 2008-09. Subsequently, based on the information received from the Investigation Wing of the Department, Mumbai that the appellant had received on-money payment on sale of plots situated at CIDCO Plots bearing Plot No.08, Sector- 56, admeasuring 450 sqm by Jai Corp Group, the Income Tax Officer, Ward- 3, Panvel, Dist.- Raigad ('Assessing Officer') issued a notice u/s 148 calling upon the appellant to file the return of income. However, no return of income was filed by the appellant in response to said notice u/s 148 of the Act. The appellant also not complied with the other notices issued u/s 143(2) and 142(1) of the Act. Therefore, in these circumstances, the Assessing Officer completed the assessment to ....
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.... 5. The ld. Counsel submitted that the addition was made by the Assessing Officer solely on the basis of surmises, conjectures and third party's statement without offering any cross-examination to the appellant. Without prejudice to this argument, it was further contended that the property sold was jointly held by 5 persons and the entire on-money consideration cannot be taxed in the hands of appellant alone. 6. On the other hand, ld. Sr. DR placing reliance on the orders of the lower authorities submitted that the assessee had not availed opportunities given by the Assessing Officer nor filed the return of income in response to notice issued u/s 148 of the Act. He also submitted that the evidence relied upon by the Assessing Officer for ....