2025 (9) TMI 225

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....Y. 2014-15. 2. The assessee has raised the following grounds of appeal: "1. Your assessee requested to condone the delay 'in filling of appeal the delay was inadvertent and unawareness circumstances. 1 hereby requested to provide a genuine ground of natural justice to heard my sight prior to finalize and penalized for unearned income. 2. The honorable commissioner has erred and upheld the ground of settlement of liability in future is not an income, in fad the assessee ready to provide fiat worth of Rs. 30,14,000 in subsequent year against sale consideration of plot purchase, rather than considering the fact that assessee has not paid any liability or purchase any flats for sales. On account of above addition LAO le....

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....t of gross receipts by Rs.30,14,000/-. As per the Assessing Officer, the above income to the tune of Rs.30,14,000/- of the assessee had escaped assessment, and accordingly a notice under section 148 of the Act was issued upon the assessee, but the assessee failed to respond to the said notice. Thereafter, multiple notices under section 142(1) of the Act were issued seeking details of the property, bank statements, investments, and sale of assets, however, the assessee did not furnish any replies or documents in response to any of these notices. In the absence of any explanation or supporting documents, and despite being given several chances, the Assessing Officer held that the assessee failed to disclose a sum of Rs.30,14,000/- as income f....

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.... of the case are that the assessee, a builder by profession, had filed his return of income for the assessment year 2014-15 under the presumptive taxation scheme of section 44AD of the Act, declaring gross receipts of Rs.92,54,031/- and taxable income of Rs.6,88,570/-. The Assessing Officer, during reassessment proceedings, observed that the assessee had purchased a property for Rs.1.35 crore, out of which a sum of Rs.1,04,86,000/- (including TDS of Rs.1,35,000/-) was paid in money terms, and the balance consideration of Rs.30,14,000/- was discharged by way of allocation of one of the newly constructed flats to the seller of the land. The Assessing Officer treated the value of Rs.30,14,000/- as undisclosed income (being undisclosed sale con....