2025 (7) TMI 1809

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....owing common grounds in all three appeals: "1. The Hon JCIT has erred in making additions under section 69A of Income Tax Act of Rs 10,50,000/- being 50% of the unexplained investment in the property without considering the fact that the Bank Statements submitted duly highlighting the payments made for purchase of the Property. 2. The Hon J CIT has erred in representation made by the assessee that She is only a co-owner in the agreement and all the investments were made by her husband. I may inform you that the Case of her husband is already completed without any additions under section 69A. 3. The Hon J C IT has erred in making addition under section 56(2)(vii)(b) of Rs 5,30,000/- being the Difference in the value as per Agreement an....

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....h her husband for total consideration amounting to Rs. 1,21,00,000/- for which the stamp duty had been paid on Rs. 1,61,93,000/- i.e the value determined by the stamp valuation authority. Upon a request received from the assessee, Ld. AO made a reference to the valuation officer to determine the value of the property. 6. However, the valuation report was not received till the date of order and, therefore, Ld. AO made an addition of the difference of Rs. 40,93,000/- between the stamp duty value and the purchase consideration paid after invoking provisions of section 56(2)(vii)(b) of the Act. As the assessee was a co-owner of the property with her husband who had made the entire investment 50% of the amount of difference, being Rs. 20,46,500....