2025 (10) TMI 857

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....enue : Shri Swapnil Choudhary, Sr. DR ORDER PER SANDEEP SINGH KARHAIL, J.M. The assessee has filed the present appeal against the impugned order dated 05.12.2024, passed under section 250 of the Income Tax Act, 1961 ("the Act") by the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, ["learned CIT(A)"], for the assessment year 2015-16. 2. In this app....

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....n 30.09.2015 for the year under consideration, declaring a total income of Rs. Nil. The return filed by the assessee was selected for scrutiny under CASS, and accordingly, statutory notices under section 143(2) and 142(1) of the Act were issued and served on the assessee. During the assessment proceedings, it was observed that the assessee had entered into a transaction of the purchase of immovabl....

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....tration of the flat. However, in the absence of details of payment made by the assessee and the copy of the allotment letter, the Assessing Officer ("AO") vide order dated 29.12.2017 passed under section 143(3) of the Act made an addition of Rs. 92,85,800/- under section 56(2)(vii)(b) of the Act. Further, the AO also rejected the claim of the assessee of set off of unabsorbed business losses under....

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....are now available with the assessee, and in this regard, brought our attention to the application seeking admission of additional evidence filed separately by the assessee before us. 6. On the other hand, the learned Departmental Representative ("learned DR") submitted that all these details, which are now furnished by the assessee, were not filed during the assessment proceedings and were also....