2022 (7) TMI 482

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....ed an immovable property in Survey No. 174/175, Madhurawada, Visakhapatnam vide sale deed No. 3349/2006, dated 30/10/2006. Since the assessee has not filed the return of income, notice U/s. 148 was issued on 14/03/2014 and served on the assessee. As there was no response to the notice issued U/s. 148, another notice U/s. 148 was issued on 20/08/2014. In response to the second notice the assessee filed the return of income along with computation of income stating that the assessee sold gold jewellery of 40 Tulas valuing at Rs. 3,25,000/- and used her own savings of Rs. 3 lakhs to purchase the above said property. Since the assessee failed to appear before the AO, the Ld. AO issued one more notice on 13/2/2015 to file the evidences by 20/02/2....

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....e. 6. For these and any other ground or grounds that may be urged at the time of hearing, it is prayed that the impugned order of the CIT(A) may please be deleted." 3.1. The assessee has also raised additional ground which reads as under: "The failure on the part of the Ld. AO to supply copy of the reasons recorded before the issue of notice U/s. 148 of the IT Act is jurisdictional defect which goes into the root of the matter, failure to do so, makes the assessment null and void." 4. The only issue in this case is with respect to sustenance of addition of Rs. 6 lakhs as unexplained money to the income returned by the assessee. The Ld. AR argued that the assessee's husband Sri SNN Bhogalingeswararao acquired the said property by w....