2024 (5) TMI 1658

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....ha ORDER PER NARENDRA KUMAR BILLAIYA (AM) 1. This appeal by the assessee is preferred against the order dated 21.12.2023 by National Faceless Appeal Centre, Delhi [hereinafter in short "Ld. CIT(A)"] pertaining to A.Y. 2015-16. 2. The grievance of the assessee read as under: - "1. On the facts and circumstances of the case and in law, the learned Commissioner of Income Tax (app....

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....ed and served upon the assessee. 4. During the course of the scrutiny assessment proceedings the Assessing Officer was seized with the information received from the Investigation Wing, Mumbai that during the search and seizure action under section 132 of the Act in the case of Runwal Group, statement of Shri Sandeep Runwal, Director was recorded in which he admitted that his group has been rece....

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....ssessee vehemently stated that the assessee has purchased the property being Flat No. 501 at Runwal Elegante but has not paid any on-money in cash for the purchase of said flat. It is the say of the counsel that the builder M/s. Runwal Projects Pvt Ltd., has confirmed the transaction. In support the counsel relied upon various judicial decisions of the Coordinate Benches wherein transactions with ....

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....s of cash received on sale of flats at various projects of the Runwal Group with names of the customers and the exact amount. The name of the assessee is at Sl.No. 21 for the Flat No. 501 at Runwal Elegante which shows the cash receipt by Runwal Group of Rs. 82,13,261/-. The contention of the counsel that it is merely an estimation defies all commercial logic because an estimated figure is always ....