2025 (2) TMI 1641

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....es out of assessment order passed by Assessing Officer under section 143(3) r.w.s. 147 of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') 28.12.2018. The assessee has raised the following grounds of appeal:- "1. Ld. CIT(A), NFAC, Delhi has erred in law and on fact to uphold AO's disallowance u/s 54 of the Act claimed by the appellant at Rs. 2,14,454/-. 2. Ld. CIT(A), NFAC, Delhi has erred in law and on fact to direct the AO to allow a cost of acquisition as on 01/04/1981 at Rs. 25/- per sq. mt. worked out at Rs. 3,78,000/- is against appellant's cost at Rs. 110/- per sq. mt. on the basis of Registered - Government approved valuer, without pointing out any detect in the report of RVO. 3. Additional ....

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....rpose of computation of capital gains, assessee computed capital gains by adopting value of land at Rs. 110/- per square meter as on 01.04.1981. The assessee adopted such value on the basis of report of Registered valuer. The Assessing Officer made a reference to District Valuation Officer ('DVO' in short) for estimation of Fair Market Value ('FMV' for short) as on 01.04.1981. Since, the report of DVO was not received by Assessing Officer and the assessment was getting time barred. The Assessing Officer adopted value of land as on 01.04.1981 at Rs. 2.25/- per square meter and made addition of Rs. 2.25/- lakh under section 50C of the Act and treated the same as income from undisclosed source. The DVO furnished his report vide report dated 29....

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....a and estimated reasonable value as on 01.04.1981 on scientific basis. The ld SR DR for the revenue submit that on both the issues the ld CIT(A) has given his categorical findings. 5. We have considered the rival submission of both the parties and have gone through the order of lower authorities carefully. We find that though assessee has raised additional ground of appeal, but at the time of submission no specific submission either for admission of additional ground of appeal or in respect of Ground No.3 of original appeal is made by Ld. AR of the assessee. Therefore, additional ground of appeal and original ground of appeal as treated as not pressed. However, on considering the submissions on Ground No.2, we find that assessee while co....