2025 (11) TMI 1675

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....d 31.01.2024 against the order of assessment passed u/s 143(3) of the Income-tax Act, 1961 (hereinafter referred to as 'the Act') dated 28.12.2018 and 31.12.2019 by the Assessing Officer, ACIT, Circle-26(2), New Delhi (hereinafter referred to as 'ld. AO'). Subsequently, the appeals were migrated to the National Faceless Appeal Centre (NFAC). ITA No. 1679/Del/24 for AY 2016-17 2. Ground Nos. 1 and 7 are general in nature and does not require any specific adjudication. 3. Ground No. 2 raised by the assessee was stated to be not pressed by the ld AR and accordingly the same is reckoned as a statement made from the Bar and dismissed as not pressed. 4. Ground Nos. 3 to 6 raised by the assessee are challenging the addition made on acc....

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....ransfer the property in the name of CPRPL. However, the Noida Authority did not transfer the property to CPRPL due to certain claims and disputes that arose with respect to the coverage and title of the said property due to which Noida authority sought clarification from the erstwhile owner of the said property. Erstwhile owner of the property duly submitted the clarification and responded with the Noida Authority. Despite that, Noida authority did not transfer the property to CPRPL. Disputes were going on between the assessee and CPRPL with regard to non-transfer of the property to CPRPL from 2003 to 2019. During FY 2019-20 relevant to assessment year 2020-21 on resolution of the dispute, the property ultimately got transferred to CPRPL fo....

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.... property to CPRPL for Rs.4.40 crores and had received advance of Rs.4 crores thereon. The property could not be registered in favour of CPRPL due to delay caused by Noida Authority and not by the assessee. The assessee had got no control over this transaction for the delay in registration caused by Noida Authority. Ultimately, when the dispute got settled in AY 2020-21, the assessee with the permission of Noida Authority, registered the property in favour of the CPRPL for Rs. 4.40 crores and capital gains thereon duly offered to tax by the assessee and taxed as such by the revenue. As far as receipt of commission and interest on unpaid commission on notional basis, pursuant to the business agreement entered into by the assessee with CPRPL,....