2023 (10) TMI 198

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....mar Jha, CIT-D.R. ORDER PER CHANDRA MOHAN GARG, JM : This appeal filed by the assessee is directed against the order of the Commissioner of Income Tax (Appeals)-3, Gurgaon dated 28.02.2022 for Assessment Year 2012-13. 2. Although, assessee has raised as many as 8 grounds in appeal but the Learned Counsel admitted that except ground nos. 5 & 6, the assessee does not want to press other ....

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....ting the cost of construction of Rs.800/- per square foot without there being any basis for the same. (iii) That the above said addition has been confirmed ignoring the detailed submissions and explanations along with the evidences brought on record by the assessee in this regard." 3. Learned Counsel submitted that the search was carried out on Mr. Padam Sain Gupta and others on 22.01.....

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....ubmitted that the Assessing Officer has made addition in the hands of assessee on the basis of facts and circumstances of the case which can't be interfered. 5. On careful consideration of the submissions, we note that the AO during the course of enquiry raised question about purchase and sale of immovable properties and to submit all the details of immovable properties and copies of wealth tax....

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....t that the present A.Y. 2012-13 is the year where on the date of search, assessments were completed but he denied relief to the assessee by referring to the judgment of Hon'ble Allahabad High Court in the case of CIT vs. Raj Kumar Arora [2014] 367 ITR 517 and Hon'ble Kerala High Court in the case of E.N. Gopakumar vs. CIT (Central), [2016] 75 Taxman.com 215 (Kerala). However, now the issue has bee....