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2023 (7) TMI 512

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..... In the Assessment Order the AO has specifically stated that during the course of assessment proceedings assessee submitted various details as called for. The details filed by assessee are examined and placed on record and the CASS and ITS data has been verified from the details submitted by assessee. Assessment Order also states that the case was selected by CASS for scrutiny in view of large investment in property, among other things. Therefore, AO was certainly satisfied with all the details provided by petitioner. If he was not, in other words, if petitioner had not furnished copy of the statement of bank accounts from which the payment was made as mentioned in the notice certainly the AO would not have passed the Assessment Order the .....

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..... ich the payment was made . Petitioner replied to this notice by its letter dated 7th September 2018 and gave following details : 5. Copy or Purchase deed for properties purchased during the year. During the year the assessee has purchased Land from the company Precision Automation and Robotics India Ltd. admeasuring 11971 sq. mt. situated at S. No. 38 Narhe for the total consideration of Rs.28.50 Crores. The said land is utilized for the construction of housing project under the name and style PARI Towers undertaken by the assessee. The Copy of the agreement for purchase of said land is attached herewith. (Refer Annexure C). 4. The payment details for the property is also given in paragraph no. 2 of the agreement, copy wher .....

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..... as entered into transaction of purchase of immovable property amounting to Rs. 28,50,00,000/- relates to Assessment Year 2016-17. In the information description the same property is mentioned twice and Mr. Manwani in fairness stated that it has been later corrected. Therefore, the only information was relating to purchase of immovable property amounting to Rs. 28,50,00,000/-. Petitioner filed a detailed reply vide its letter dated 27th March 2023. Petitioner raised various grounds including the fact that the same transaction came under complete scrutiny before the Assessment Order under Section 143(3) of the Act was passed. Petitioner also submitted that petitioner s case was selected for scrutiny under CASS for the same property and petiti .....

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..... the payment was made. In its reply dated 7th September 2018 petitioner has given details of property purchased including copies of Purchase Deed. The Purchase Deed also contains details of payments made. In the Assessment Order dated 29th November 2018 the Assessing Officer has specifically stated that during the course of assessment proceedings assessee submitted various details as called for. The details filed by assessee are examined and placed on record and the CASS and ITS data has been verified from the details submitted by assessee. The Assessment Order also states that the case was selected by CASS for scrutiny in view of large investment in property, among other things. Therefore, the Assessing Officer was certainly satisfied with .....

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