2025 (10) TMI 1147

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.... CIT DR ORDER PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the assessee pertaining to Assessment Year 2016-17 challenging the Final Assessment Order dated 27/01/2025 passed by Assistant Commissioner of Income Tax, Circle International Taxation 2(2)(1) u/s143(3) Section 147r.w.Section 144C(13) of the Income Tax Act, 1961 ('Act' for short). 2. Brief facts of the case....

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....mitted that A.O. erred in treating the amount of Rs. 1,23,00,000/- as unexplained investment u/s 69 of the Act without any evidence on record and ignoring the fact that the Assessee has not invested any sum existing Rs. 1,23,00,000/- in purchase of the property. The Ld. Counsel has also taken us through the registered sale deed placed in the Paper Book and contended that the sale deed has been exe....

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....d the Assessee denied to have purchased the property for Rs. 1,23,00,000/-. To substantiate the said claim, Assessee produced the registered sale deed before the authorities below and also before us, wherein the sale consideration has been mentioned as Rs. 30,00,000/- and the said sale consideration is more than the prevailing circle rate at that point of time. There is no material brought on reco....