2026 (3) TMI 1024

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....ax Act, 1961 (hereinafter referred to as the "Act"), dated 13.08.2022 for AY 2020-21. 2. Grounds taken by the assessee are reproduced as under: 1. "Whether the Id CIT-A,NFAC was justified by passing the order without affording reasonable opportunity of being heard and personal hearing despite the admitted facts that there are so many glitches on portal resulting details/submissions couldn't be uploaded. 2. Whether the Ld CIT-A(NFAC) was justified by upholding the Assessment order on the issue of invoking section 56(2) on the difference of Rs. 2,28,41,000/-due to stamp valuation and declared consideration without considering the nature of property its location as the property whch may have to be transferred to, MCGM,....

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....duced in the impugned assessment order whereby it is categorically mentioned that the purchase of the impugned property is made jointly with her son having equal share. However, the addition made is of 100% difference and not equivalent to the share of the assessee in the said property. 3.1. Before the ld. Assessing Officer, assessee had also requested for making a reference to the District Valuation Officer (DVO) of the Department by invoking the provisions of section 56(2) which was not accepted. Assessee moved her first appeal before the ld. CIT(A) reiterating the submissions made before the ld. Assessing Officer. Ld. CIT(A) dismissed the appeal of the assessee and sustained the addition observing that assessee did not furnish the det....

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....ed on 01.05.2024. It is also noted that assessee is an undergraduate and was dependent on her spouse and tax consultant for making the required compliances. According to her, there is no negligence or wilful attempt to avoid furnishing details of documents before the first appellate authority as well before the Assessing Officer. 4. We have considered the material on record and submissions made before us. We have also gone through the orders of the authorities below. Admittedly, it is a fact on record that assessee had made submissions, both at the assessment stage as well as at the first appellate stage, which were not considered in proper perspective by making addition of the entire difference in her hands even though it was repeatedly....