2021 (8) TMI 1396

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.... raised identical grounds of appeal in all the cases, therefore with the consent of parties all the appeals are clubbed, heard and are decided by common order. For appreciation of facts appeal for A.Y. 2014-15 in ITA No. 41/RPR/2021 has been treated as lead case. The assessee has raised the following grounds of appeal:- "1. The order passed by ld. Pr.CIT is illegal, authorities below initio void & unsustainable as the same has been passed without giving any opportunity of hearing to assessee, contrary to mandatory requirement of law. Consequent revision order is illegal & is liable to be quashed/annulled. 2. The assessment order passed by AO is neither erroneous nor prejudicial to the interest of Revenue. Ld. Pr.CIT erred ....

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....amp Valuation Authority and that the provisions of section 43CA are attracted. The ld. PCIT also noted that there is a difference of sale consideration and value determined by Stamp Valuation Authority in respect of 12 such persons of Rs. 33.02 lakhs and that the AO failed to verify and applying the correct law. The ld. PCIT considered the reply of the assessee and the same is not satisfactory. The ld. PCIT set aside the assessment order and directed to verify the sale deed for the year under consideration and pass the assessment order afresh by giving adequate opportunity to the assessee. Aggrieved by the order of ld. PCIT the assessee has filed the present appeal before this Tribunal. 3. We have heard the submissions of ld. Authorized ....