2025 (9) TMI 609

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....rder passed u/s 147 r.w.s. 144 r.w.s. 144B of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). 3. Facts of the case, in brief, are that as per information available with the department for financial year 2015-16 it was seen that the assessee sold immovable property for a total consideration of Rs. 52,57,38,505/-. Since the assessee had not filed his return of income and has not disclosed the income in respect of the above transactions, the Assessing Officer, after recording reasons, reopened the assessment as per the provisions of section 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act'). Accordingly notice u/s 148 of the Act was issued to the assessee on 31.03.2021. However, there was no compliance fro....

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....s, confirmation deeds, cancellation deeds, supplementary agreements etc which are mentioned in the power of attorney itself, he was under the bonafide belief that he is not liable to any tax. Further the Pate group has disclosed income from sale of such properties in their returns and the assessee is no way liable for any tax. He submitted that since the total income of the assessee is below the taxable limit, he was not liable to file any income tax return. Further, the various notices issued by the income tax department were not noticed by him since he was not acquainted with the technology. He submitted that since both the orders have been passed ex-parte, therefore, in the interest of justice the assessee should be given an opportunity ....