TaxTMI 
TaxTMI 
2026 (2) TMI 81
X X X X Extracts X X X X
X X X X Extracts X X X X
....CIT(A)"], for the assessment year 2017-18. 2. The solitary grievance of the assessee is against the addition made under section 56(2)(vii)(b) of the Act. 3. We have considered the submissions of both sides and perused the material available on record. The brief facts of the case are that the assessee is an individual, and for the year under consideration, filed her return of income on 30.09.2017, declaring a total income at Rs. 4,26,590/. On the basis of the information received from DIT(I & CI), Mumbai that the assessee has entered into a transaction of purchase of immovable property, wherein the assessee has not transacted as per the stamp value rate of the property, notice under section 148 of the Act was issued to the assessee on ....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... that the assessee is a senior citizen and is unable to read and write in English. It was further submitted that she is literate only in Urdu, which significantly limits her ability to independently manage and comply with tax-related formalities. Thus, she is compelled to rely on others to handle her tax compliance requirements. It was further submitted that since the notices were issued by the learned CIT(A) through ITBA portal, due to her limitations, the assessee could not respond to any of the notices issued by the learned CIT(A). On merits, the learned AR submitted that pursuant to the query raised under the RTI Act, the assessee came to know that the price of a similar property in a similar locality in MHADA is much below the consider....
X X X X Extracts X X X X
X X X X Extracts X X X X
....,- (i) without consideration, the stamp duty value of which exceeds fifty thousand rupees, the stamp duty value of such property; (ii) for a consideration which is less than the stamp duty value of the property by an amount exceeding fifty thousand rupees, the stamp duty value of such property as exceeds such consideration: ...................... (c) ................... Provided that where the stamp duty value of immovable property as referred to in sub-clause (b) is disputed by the assessee on grounds mentioned in sub-section (2) of section 50C, the Assessing Officer may refer the valuation of such property to a Valuation Officer, and the provisions of section 50C and sub-section (15) of section....
X X X X Extracts X X X X
X X X X Extracts X X X X
....en made before any other authority, court or the High Court, the Assessing Officer may refer the valuation of the capital asset to a Valuation Officer and where any such reference is made, the provisions of sub-sections (2), (3), (4), (5) and (6) of section 16A, clause (i) of subsection (1) and sub-sections (6) and (7) of section 23A, sub-section (5) of section 24, section 34AA, section 35 and section 37 of the Wealth-tax Act, 1957 (27 of 1957), shall, with necessary modifications, apply in relation to such reference as they apply in relation to a reference made by the Assessing Officer under sub-section (1) of section 16A of that Act. Explanation 1.- For the purposes of this section, "Valuation Officer" shall have the sam....