2025 (8) TMI 39

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...., JUDICIAL MEMBER: This is an appeal filed against the order dated 27-06- 2024 passed by National Faceless Appeal Centre (NFAC), Delhi for assessment year 2013-14. 2. The grounds of appeal are as under:- "1. The impugned assessment made u/s 147 of the Income Tax Act is invalid and void ab initio as the notice u/s 143(2) issued during the course of proceeding u/s 148 was time barred and therefo....

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.... assessee along with other 11 co-owners sold immovable property/land bearing survey no. 928/1/A situated village Ola, Kalol for consideration of Rs. 46,00,000/- during the assessment year 2013-14. As per the information, stamp duty paid for the sale transaction was Rs. 9,29,500/-, accordingly value of the property as per stamp duty comes to Rs. 1,89,69,388/-. There was a difference of Rs. 1,43,69,....

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....being 7.142% share to Rs. 1,89,09,388/-. 4. Being aggrieved by the Assessing Officer, the CIT(A) dismissed the appeal of the assessee. 5. The ld. A.R. submitted that the impugned assessment made u/s. 147 of the Income Tax Act is invalid and void ab initio as the notice u/s. 143(2) issued during the case of proceedings u/s. 148 was time barred and therefore the ld. A.R. has assumed invalid jurisd....

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....d more than the jantry value, provisions of section 50C will not be applicable. 8. The ld. D.R. relied upon the assessment order and the order of the CIT(A) 9. We have heard both the parties and perused all the relevant material available on record. There is a delay of 54 days for which the assessee has filed application and the same is condoned. It is pertinent to note that as per old jantri ra....