TaxTMI 
TaxTMI 
2025 (11) TMI 1589
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....08.03.2024 passed u/s 147 R.W.S. 144B of the Income Tax Act, 1961 (hereinafter referred as 'the Act') by the ITO, Ward-44(1), Delhi (hereinafter referred to as the Ld. AO). 2. On hearing both the sides, we find that the case of the Revenue is that the assessee has been erroneously benefitted by the ld. CIT(A) as the source of the source of her husband's agricultural activities has not been examined. We find that the Revenue has also raised a ground that additional evidences were accepted without giving the AO an opportunity to contest. 3. On appreciating the material before us and the submissions, we find that the assessee is a senior citizen and there is interest free interest income and no return for AY 2016-17 was filed and the ass....
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.... the Act and the same was deleted by the ld. CIT(A) by making the following findings in para 7:- "7. I have carefully gone through the assessment order, statement of facts, grounds of appeal and submission of the appellant. 7.1 It has been observed from the assessment order that the appellant had not filed her return of income for the year and consideration and further there was an information during the financial year that the appellant had purchased immovable property for Rs. 1,05,00,000/-. During the proceedings u/s 148A of the Act, the appellant sought adjournment to the show cause notice issued u/s 148A(b) of the Act but failed to comply to the notice issued. The notice u/s 148A(b) was also delivered through speed pos....
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....rges. Also it is seen from the bank statement of Shri Ram Narain Chug that he is receiving money from various parties and also appears to be carrying some business activity. However, the appellant stated that he is into agricultural activity but failed to produce any evidence in this regard. The appellant furnished Form-J in the name of her husband and it was seen that the total amounts of Form-J stood at Rs. 27,43,331/- which also does not commensurate with the amount of purchased immovable property. As the appellant failed to submit the documentary evidences requisitioned, the assessment was completed u/s 147 rws 144 of the Act after making addition of Rs. 1,10,25,000/-. In respect of unexplained investment u/s.69 and added to the total i....
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....tement showing the amount of Rs 52,70,000/- paid by her for purchase of the immovable property in question. She had clarified that although she held 50 % ownership share in the said property valued at Rs 2,10,00,000, however, she had only made payment of Rs 52,70,000/- towards the said property. She further stated that her balance share was paid by her husband Mr Ram Narain Chugh on her behalf and that the same is mentioned in the sale deed of the property. She had submitted bank statement of her husband evidencing the said payment and copy of Form-J evidencing that he was carrying out agricultural activities. Further, she had stated that the source of funds amounting to Rs 52,70,000/- paid by her was the amounts of Rs 29,14,800 and Rs 20,3....