2025 (7) TMI 1111

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....h Ramawat, Sr. DR. ORDER PER RENU JAUHRI [A.M.] :- This appeal is filed by the assessee against the order of the Ld. Commissioner of Income Tax (Appeals)/ National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as CIT(A)] dated 27.02.2025 passed u/s. 250 of the Income-tax Act, 1961 [hereinafter referred to as "Act"] for Assessment Year [A.Y.] 2017-18. 2. The assessee has....

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....respond to notice under section 148A of the Act. 4. The appellant request to delete the addition confirmed by the CIT(A)." 5. The appellant craves to add, alter or omit any or all of the above grounds of appeal before or at the time of hearing of the appeal." 3. The assessee has subsequently taken the following additional ground: "6. The proceeding of re-assessment, c....

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....the property was Rs. 88,63,000/-. Observing that the provisions of Section 50C are applicable with regard to difference of Rs. 28,63,000/-, Ld. AO held that income chargeable to tax u/s. 56(2)(vii) of the Act had escaped assessment and accordingly a notice u/s. 148 of the Act was issued. Assessment was completed after adding Rs. 28,63,000/- to the assessee's income u/s. 56(2)(vii)(b) of the Act. A....

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....ice can be issued after three years unless the income chargeable to tax which has escaped assessment amounts to Rs. 50 lacs or more. In this case, the amount involved is only Rs. 28,63,000/- and therefore the assessment could not have been reopened after the expiry of three years from the end of the assessment year. 6. We have heard the rival submissions and carefully considered the applicable ....