2024 (6) TMI 688

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nt : Shri Om Parkash, Sr. DR ORDER PER S.RIFAUR RAHMAN, AM: 1. This appeal has been filed by the Assessee against the order of Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi ["Ld. CIT(A)", for short], dated 22/12/2023 for Assessment Year 2018-19. 2. The brief facts of the case are, the assessee filed its return of income on 28/08/2018 declar....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....is an agricultural land and is situated outside the Municipal Area. He also submitted that the details of the property and mode of payment the same is reproduced by the AO at page 2 of the order. Subsequently, the assessee was asked to provide documentary proof of the above said agricultural land. However, the Assessing Officer not received any documentary evidences and accordingly, he proceeded t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....n of Hon'ble Madras High Court, he dismissed the appeal filed by the assessee. 5. Aggrieved with the above order, the assessee is in appeal before us raising following grounds of appeal:- "The Commissioner of Income-tax (Appeals) at National Faceless Appeal Centre (hereinafter referred to as the CIT(A)-NFAC) erred in upholding the action of the Officer at the National e-assessment Cent....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....nd deeming provision of section 56(2)(x) will not apply. Further, he submitting that the transaction entered by the assessee which is the Arms Length Price and there is no relationship with the seller. He brought to our notice the findings of the Ld. CIT(A) from page 12 to 14 of the order. 7. On the other hand, the Ld. DR relied on the findings of the lower authorities and submitted that the Ld....