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2024 (5) TMI 1081

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....l of the Assessee arises out of the order of the Learned Commissioner of Income Tax (Appeals), Ghaziabad [hereinafter referred to as 'Ld. CIT(A)'] in Appeal No.103/2017- 18/Gzb, dated 30/09/2019 against the order passed by Income Tax Officer, Ward-2(5), Ghaziabad (hereinafter referred to as the 'Ld. AO') u/s 147/144 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') on 30/09/2019. ....

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....d for a sum of Rs.1,42,55,199/- which was not disclosed the same and was added in the income of the assessee by complete assessment u/s 144 of the Act. 5. Aggrieved by the order of the Assessing Officer, the appellant assessee preferred appeal before CIT(A) with the grounds that the assessment order was without complying with the mandatory conditions u/s 147 to 151 as envisaged under the Income T....

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....de sale deed dated 23/02/2010 for sale consideration of Rs.1,10,00,000/- however the stamp duty value was 1,42,55,199/- (Page no.11-52 of the paper Book). The appellant submits that the sale proceeds of agricultural land was invested for purchase of agricultural land and residential house property. The appellant has purchased agricultural land of Rs.43,55,150/- through 5 registered purchase deeds ....

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.... by the assessee to establish the fact that agricultural land at the time of sale was not a capital assets and that otherwise the sale consideration was invested in accordance with provisions of section 54F was rejected for the reason that the same were not placed before the Assessing Officer. At the same time CIT(A) has directed the Assessing Officer to compute the capital gain after giving benef....