2026 (2) TMI 1120

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.... For the Revenue : Ms. Kavita Kaushik, Sr. AR ORDER PER AMIT SHUKLA (J.M): This appeal has been preferred by the assessee against the order dated 16.02.2024 passed by NFAC, Delhi, in relation to the assessment framed under section 143(3) of the Income-tax Act, 1961, for the assessment year 2018-19. 2. At the outset, it is noticed that the appeal has been filed with a delay of 458 da....

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....dling the firm's financial and tax matters also resigned without handing over complete records. 4. Owing to this combination of adversities personal tragedy, pandemic disruptions, serious illness, and loss of professional support, the appeal could not be pursued in time. The deponent has affirmed that the delay was neither deliberate nor negligent, but entirely beyond her control. 5. Having ....

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....6,84,000/-. He invoked section 56(2)(x) and made an addition of Rs.45,00,000/-. Further, upon examining the Joint Development Agreement (JDA), he held that though the assessee disclosed only Rs.3,00,00,000/- as sale consideration, the stamp valuation was Rs.9,04,16,000/-. Treating the difference of Rs.6,04,16,000/- as unoffered capital gain, he brought the same to tax. 7. In appeal, the ld. CIT....

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....ition of the deponent and pandemic disruptions, these facts could not be properly brought before the authorities earlier. 9. The learned Departmental Representative, with fairness, did not seriously object to the restoration of the matter for fresh consideration. 10. We have considered the rival submissions. It is evident that the assessment order was framed without a proper appreciation of ....