2025 (9) TMI 437

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.... of the Income-tax Act, 1961 (hereinafter referred to as "the Act") dated 08.05.20225 by the Assessing Officer, Dy. CIT, CPC-TDS (hereinafter referred to as "ld. AO"). 2. The assessee has raised the following grounds of appeal:- "1. The Appellant craves leave for adducing necessary evidence, amendments and explanations including written one to the aforesaid grounds and also raise additional grounds in the course of hearing of the appellate proceedings. 2. That the Ld. CIT(A) has erred in law and on facts in upholding 2 the action of the Ld. CPC, TDS in raising the demand for an amount of Rs. 3,54,180/- in an order passed u/s 154 of the Act. 3. That having regards to facts and circumstances of the case, the Ld. ....

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.... was mentioned with long term capital gain claimed of Rs. 87,50,000/-. The ITO, International Taxation, Gurgaon, being the competent authority, allowed deduction of tax at source @3% while making payment for purchase of property. In this certificate, the total long term capital gain figure for Rs. 87,50,000/- as fully attributable to Shri Bhupender Singh Yadav. It was submitted that this certificate was obtained inadvertently in the name of Shri Bhupender Singh Yadav alone instead of separately obtaining 2 certificates for Shri Bhupender Singh Yadav (50% portion) and Shri Sumit Yadav (assessee herein) for remaining 50% portion. On 26.11.2021, the seller obtained a lower deduction certificate @3% in respect of payment pertaining to the asses....