2026 (5) TMI 833

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....e Respondent/Revenue : Shri Rajesh Kumar Dhanesta, Sr. DR ORDER PER AMITABH SHUKLA, AM, This appeal by the assessee is directed against the order of National Faceless Appeal Centre/Ld. Commissioner of Income Tax (Appeals), New Delhi, [hereinafter referred to as 'ld. CIT(A)] dated 25.08.2025 arising out of assessment order dated 05.12.2017 passed under section 143(3) of the Income Tax Act,....

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....was drawn to para-8 of the assessment order, wherein, the ld. AO had denied the claim of deduction on the premise that the assessee was having more than one residential unit and that the alleged transfer of property to the son was a sham transaction attempted to avoid taxation. The ld. Counsel further drew our attention to para-5.4 and 5.5 of the appellate order, wherein, the ld. CIT(A) concluded ....

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.... 5. We have noted that the only controversy in the case was the denial of deduction under section 54F to the assessee by the ld. AO of Rs. 93,35,464/-. This was the addition for which the assessee had approached ld. CIT(A). The AO had concluded that the assessee was having more than one residential unit and that the alleged transfer of property to the son was a sham transaction attempted to avoid....