2025 (6) TMI 1397

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....SONJOY SARMA: This appeal is filed by the assessee against the order dated 22.11.2024 passed by the DCIT Circle Intl. TXN, TVM (hereinafter referred to as 'CIT(A)'] u/s 147 r.w.s 144C(13) of the Income Tax Act ('Act') for the assessment year 2015-16. 2. Brief Facts of the case are that during the relevant assessment year, the assessee had sold two agricultural properties totaling to Rs. 15,59,00....

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....ter at circle rate value as prescribed. The assessee NRI was not familiar with a local registration practice, therefore, full consideration of Rs. 34,00,000/- was received through transparent banking channel as it already disclosed by the assessee before the Assessing Officer. Therefore, the provisions of section 69 of the Act which shifts onus to the assessee to explain the nature and source of t....

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....at the entire Rs. 34,00,000/- came from the properties sold to the purchaser. Moreover, valuation of the stamp duty versus actual consideration, the difference arose solely because of the purchaser chosen to register a deed at the circle rate and stamp duty value was determined by the said authority for which the seller cannot compel the purchaser to reflect negotiated price. Since the assessee wa....