TaxTMI 
TaxTMI 
2025 (2) TMI 1520
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.... Section 250 of the Income-tax Act, 1961 [hereinafter referred to as "the Act" for short], for Assessment Year (AY) 2019-20. 2. The Assessee has taken following grounds of appeal:- "1. On facts and circumstances of the case and in law, the order passed by the Ld. CIT(A), NFAC, Delhi is bad in law, illegal besides being in violation of principle of natural justice & equity as passed without considering the material already placed on record, as such it is liable to be quashed and set aside. 2. On facts and circumstances of the case and in law, the Ld. CIT(A) has grossly erred in sustaining addition of Rs. 2,51,73,000/- on account of alleged unexplained investment u/s. 69 by the A.O., when there is no justification in sust....
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....y stated that "Shri Ankur C. Patel PAN-AMPPP1214N purchased property for Rs. 4,81,00,000 from Shri Jagdish Sharma in the SKY CITY VERNIS project, but the SRO valuation is Rs. 2,29,27,000, implying a cash/on-money difference of Rs. 2,51,73,000.", but the property was jointly purchased with his late father for Rs. 2,29,27,000/- under a registered deed (No. 8077 of 2018, dated 03.07.2018), with payment made through M/s. Safal Goyal Realty LLP; therefore, the department's claim of Rs. 4,81,00,000/- towards purchase of property is factually incorrect. 6. The Ld. DR on the other hand relied upon the orders of the authorities below. 7. Heard both the parties and perused the material available on record. 8. We have gone through the rea....
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....in the prescribed manner and setting forth such other particulars as may be prescribed; and the provisions of this Act shall, so far as may be, apply accordingly as if such return were a return required to be furnished under section 139; Provided that no notice under the said section shall be issued unless there is information with the Assessing Officer which suggests that the income chargeable to tax has escaped assessment in the case of the assessee for the relevant assessment year and the Assessing Officer has obtained prior approval of the specified authority to issue such notice." b. Further, as per Explanation 2 u/s. 148, "For the purposes of this section, where,- i. the Assessing Officer is satisfied, with ....
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....nclusion: a. As the search action was initiated under section 132 and after the 1st day of April, 2021, therefore, as per clause iv of Explanation 2 to section 148, the AO is deemed to have information for A.Y. 2019-2020. b. Further, the provisions of section 148A are not applicable in this case. Since three years have not elapsed from the end of relevant assessment year, thus as per provisions of Section 149 r.w.s 148 r.w.s 151, the specified authority to grant approval is Pr.CIT -3, Ahmedabad. d. Shri Ankur C. Patel PAN-AMPPP1214N has bought the property of Rs. 4,81,00,000/- from JAGDISH SHARMA in project SKY CITY VERNIS. However, as per valuation of SRO, the value of the said property is of Rs. 2,29,27....