2026 (6) TMI 1170

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.... Raskar, (SR. DR) ORDER PER NARENDER KUMAR CHOUDHRY, JUDICIAL MEMBER: This appeal has been preferred by the assessee against the order dated 30.06.2025, impugned herein, passed by National Faceless Appeal Centre (NFAC), Delhi/ Ld. Commissioner of Income Tax (Appeals), (in short 'Ld. Commissioner') u/s. 250 of the Income Tax Act, 1961 (in short 'the Act') for the A.Y. 2018-19. 2. At the....

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....re this Hon'ble Tribunal. 5. I request your Honour to kindly condone the delay of 172 days and admit the appeal as the delay was neither intentional nor deliberate and was on account of a misunderstanding. I pray before your Honour to take a lenient view in the matter and that the Appeal may kindly be admitted on the merits of the case as there was no mala fide intention." ....

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....ssessing Officer vide assessment order dated 27.09.2021 made the addition of Rs. 2,16,70,000/- being differential amount between the stamp duty valuation and consideration shown by the assessee as per the provisions of Section 56(2)(x) as "income from other sources". However, the Assessing Officer in para no. 11 of the assessment order mentioned as under: "on receipt of report from Valuat....

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.... amount between the FMV of the property as per DVO report (Rs. 6,11,69,000/-) and agreement value as declared by the assessee to the tune of Rs. 5,60,00,000/- is of Rs. 51,69,000/- which is 9.23% and less than the prescribed permissible variation upto 10%, as specified in the proviso to Section 50C of the Act and other similar provisions including Section 56(2)(x) of the Act. 11. Therefore, in ....