2025 (4) TMI 1855

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....DER This assessee's appeal for assessment year 2012-13, arises against the Commissioner of Income Tax (Appeals)/National Faceless Appeal Centre [in short, the "CIT(A)/NFAC"], Delhi's DIN and order no. ITBA/NFAC/S/250/2023-24/1059829068(1), dated 17.01.2024 involving proceedings under section 143(3) r.w.s. 147 of the Income-tax Act, 1961 (hereinafter referred to as 'the Act'). Heard both the ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....on record the above stated sale deed dated 11.05.2012. Necessary presumption which would arise in such an instance, going by the Mrs. Malini Ramnath Rele Vs. Third Income-Tax Officer on [1994] 49 ITD 43 (TM) (MUM), is that keeping in mind the time span between the assessee's cash deposits and the sale deed would indicate that this cash deposit represents cash consideration only. The fact, however,....