2025 (2) TMI 1393

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....ue of notice u/s. 148A(b), order u/s, 148(A)(d) & notice u/s. 148 by the Ld. Income Tax Officer-28(1)(1), Mumbai is invalid and bad in law. (b) The order passed u/s. 147 of the Act by the Ld. Income Tax Officer-International Tax -4(2)(1), Mumbai dated 19/12/2024 is invalid and bad in law. 2. The Ld. AO erred in law & facts in adding a sum of Rs. 58,01,023/- w/s. 69 of the Act merely on surmises and conjectures without appreciating the facts of the case & documents submitted by the appellant. 3. The Ld. AO & DRP erred in appreciating that the appellant had duly discharged the onus of establishing the nature & source of the immovable property jointly acquired. 4. All the above grounds are independent and wi....

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....f Rs. 88,42,898/- towards the purchase of the property in question was paid by Shri Deep Sethi (father of the assessee). While the payment of Rs. 30,41,875/- made from his (father's) account in SBI was treated as explained by the Ld. AO, balance payment of Rs. 58,01,023/- which was made by Shri Deep Sethi from his account in Punjab National Bank was not accepted. Ld. AO, accordingly, proceeded to treat this amount as unexplained u/s 69 of the Act with the following observations: "The assessee has submitted home loan sanction letter and loan disbursement history of Rs. 99,94,030/-. Further, the assessee has made payment of Rs. 26,11,028/- from his State Bank of India NRE account no. 31181966099. The assessee has made payment of Rs. ....