2026 (1) TMI 472

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....ef facts of the case are that the assessee had filed return of income for A.Y 2018-19 on 31.08.2018, declaring total income of Rs. 2,81,870/-. The case was selected for scrutiny under CASS. In the course of assessment proceeding, the Assessing Officer found that the assessee had purchased an immovable property during the year for a consideration of Rs. 63,24,500/-. However, the stamp duty value of the property was 87,81,709/-. The difference of Rs. 24,57,209/- was considered as other income and added under the provision of section 56(2)(vii)(b) of the Act. The assessment was completed u/s. 143(3) of the Act on 19.02.2021 at a total income of Rs. 27,39,075/-. 3. Aggrieved with the order of the Assessing Officer, the assessee had filed an ....

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....t though the property was purchased for a consideration of Rs. 63,24,500/- during the year, the first payment for purchase of the property was made on 18.02.2013 vide cheque of Rs. 1,00,000/-. Thereafter, the periodical payments were made during the years 2014 to 2017. The assessee had thus agreed to purchase the property on 18.02.2013 itself, when the first payment was made by him. The Ld. AR submitted that the stamp duty value of the property as on date of the agreement i.e. on 18.02.2013 should have been considered by the Assessing Officer for making the addition, if any, under the provisions of section 56(2)(vii)(b) of the Act. 6. Per Contra Shri Ajay Uke, Sr. DR supported the order of the Assessing Officer. He submitted that no agre....