2025 (4) TMI 1904

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....m. Rinku Singh, CIT, DR ORDER PER BENCH : All these captioned appeals by the assessee are against the separate orders of the Ld. Commissioner of Income Tax (Appeal), Patna-3 [hereinafter referred to as "the Ld. CIT(A)"] vide order nos. ITBA/APL/S/250/2022- 23/1047715787(1), ITBA/APL/S/250/2022-23/1047715732(1), ITBA/APL/S/250/2022-23/1047715692(1), ITBA/APL/S/250/2022- 23/1047715648(1), I....

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....ion that the returns filed by the assessee consequent to the notice u/s. 153A came to be processed and a building which was under construction by the assessee namely M/s. Sharan Complex was subjected to valuation. It was the submission that the assessee till 31.03.2017 disclosed a value of Rs. 3,75,79,867/-. The DVO has valued cost of construction of the building at Rs. 4,95,05,725/- for this peri....

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.... have held that as no incriminating material has been used nor found in the course of search which has led the addition, the assessment passed u/s. 153A is liable to be quashed. 4. In reply, the Ld. CIT, DR drew our attention to the question no. 10 of the statement recorded u/s. 132(4), which reads as follows: "10. When was Sharan Complex constructed? What was the cost of construction ....

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....the facts of the assessee's case. 6. We have heard the rival contentions. A perusal of the statement recorded u/s. 132(4) as extracted above would clearly show that the assessee has categorically admitted that the investments in the building have been shown in the Balance Sheet of the assessee. There is no statement in the statement u/s 132(4) recorded that the assessee has made undisclosed inv....