2025 (3) TMI 2192

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....er: "1. Whether the NFAC has erred on facts and in law by allowing the appeal of the assessee without appreciating the facts of the case. 2. That the NFAC has erred in law and facts by considering the entire assessment proceedings as Void-ab-Initio instead the same can be corrected by taking recourse to the provisions of Section 292B of the Act. 3. Whether the NFAC has erred in law by setting aside the findings of the AO and deleting the addition of Rs. 1,87,50,000/- made u/s 69 of the Income Tax Act, 1961 as the same remained unexplained during the assessment proceedings in that there are no evidences or findings that the said investments stood included in the books of accounts. 4. Whether the NFAC had e....

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...."As per the sale deed available with this office it is seen that the assessee purchased a residential house (30% share), H. No. 1008. Sector BC, built up on old plot No. 9. Sector BC, Chandigarh for a consideration of Rs. 1,87,50,000/- on 27.07.2015 i.e. during the assessment year 2016-17. No explanation regarding source of these investments have been furnished. The onus was upon the assessee to prove the source of investment made by the assessee in purchase of the property supra. As such, the assessee has failed to discharge his duty and also failed to explain the source of these investment made by him; hence, the amount of Rs. 1,87,50,000/- remained unexplained and is deemed as unexplained of investment u/s 69 of the Act and is added to t....

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....nse that the assessee has filed a copy of return of income which was already filed before the A.O. before issuance of notice u/s 148. The A.O. had taken up this case as where according to him, no return of income was filed and no details of the purchases of property was shown but the assessee filed brief during proceedings before the ld. CIT(A) bringing it on record that the return was already filed before the A.O. wherein the details of the property, its purchases and deduction of TDS thereon was already on the record of the A.O. 7. Keeping in view these facts, we are of the considered view that the findings given by the ld. CIT(A) is very clear and categorical and it needs no interference. 8. There is a CO in this appeal and grounds....