2025 (10) TMI 1017

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....t of an order passed by the Assessing Officer dated 21/03/2024, u/s 147 of the Income Tax Act, 1961. 2. Grounds of appeal raised by the assessee are as follows: 1. The order passed by the Ld. CIT (Appeals), NFAC dated 18.08.2025 is bad, illegal and in violation of principals of natural justice. The assessee has right from day one requesting for a copy of Satisfaction Note of A.O. of searched person and Jurisdictional A.O along with a copy of incriminating document and an opportunity for cross examination, which has never been provided. Ignoring this facts, the Ld. CIT (Appeals) has confirmed the order u/s. 147 dated 21.03.2024 which is prayed to be quashed. 2. Notice u/s. 148 has been issued by J.A.O. on 31.03.2023 and ....

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....ws: In this appeal, the assessee has challenged the addition of Rs. 1,68,667/- made u/s 69A on the ground that there is no valid incriminating material or direct evidence to prove that the assessee made any cash payment (on-money) in relation to the purchase of property. In this case Return of Income for the year under consideration was e-filed by the assessee, against the notice, under section 148 of the Act, declaring therein total taxable income of Rs. 9,82,560/-. A search and seizure action were conducted on 10.02.2022 in the case of Shivalik, Shilp and Sharda Group. During the course of search and seizure action, the premise of Shri Manish Brahmbhatt, Bhaumik Panchal who is a real estate broker was also covered u/s 132 of the Act. The ....

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....imited to 1/3rd only, hence the share of assessee in paying onmoney was restricted to Rs. 1,68,667 (1/3rd of 5,06,000) and made addition in the hands of the assessee at Rs. 1,68,667/-, under section 69A r.w.s. 115BBE of the Act. 5. Aggrieved by the order of the assessing officer, the assessee carried the matter in appeal before the ld CIT(A), who has confirmed the action of the assessing officer. The ld.CIT(A) held that no source of the alleged cash payment has been explained by the assessee, and no rebuttal evidence has been placed on record to counter the seized material or to support her claim that no on-money payment was made. Therefore, ld.CIT(A) held that assessing officer has rightly invoked the provisions of section 69A and treat....