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2025 (6) TMI 941

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.... JAUHRI A.M. :- This appeal is filed by the assessee against the order of the National Faceless Appeal Centre, Delhi [hereinafter referred to as "CIT(A)"] dated 09/02/2024 passed u/s. 250 of the Income-tax Act, 1961 [hereinafter referred to as "Act"] for Assessment Year [A.Y.] 2016-17. 2. The assessee has raised the following grounds of appeal: "Being aggrieved by the orders of the Assessment ....

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....nd in law, learned Commissioner of Income-tax (Appeal) erred in upholding action of the Assessing Officer in treating the redevelopment agreement as transfer of immovable property without appreciating the fact that, Assessee neither transferred any property, nor did it part with possession of the building with the developers, but entered into this redevelopment agreement in its capacity as a co-op....

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....ntary evidences, the assessment was completed u/s. 144/147 r.w.s. 144B of the Act at an income of Rs. 6,52,91,758/- after making additions on the above issues. Aggrieved with the order of Ld.AO, the assessee preferred an appeal before Ld. CIT(A). After considering the assessee's submissions, Ld. CIT(A) confirmed the addition on account of capital gains to the extent of Rs. 6,52,77,000/- vide order....

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....amp duty of Rs. 32,63,850/- for registration purposes. Before the Ld.AO as well as Ld. CIT(A), the assessee explained that the developer did not commence the work even after a lapse of 10 years. Even otherwise, under the redevelopment agreement there was no transfer of property and the agreement value mentioned therein was merely for arriving at the stamp duty payable for the purposes of registrat....