9911796707
TMI Blog2024 (2) TMI 281X X X X Extracts X X X X X X X X Extracts X X X X ..... ed to add the difference between the consideration specified in the sale deed and the guideline value as additional income and also initiated proceedings in respect of penalty. This approach is clearly unsustainable. Addition on account of rent receipts, the petitioner provided an explanation that rent was received towards a residential house property and that the income was duly disclosed. The petitioner further explained that tax had been wrongly deducted under Section 194IB instead of Section 194C of the Income-tax Act and that the petitioner should not be put to prejudice on that account. Contractual receipt which had been shown as business income. These explanations have been brushed aside as not satisfactory without providing an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 24.02.2023. It was further stated that the addition should not be made without a waiting the valuation report. An explanation was also provided with regard to the proposed 2nd and 3rd additions and it was contended that such additions are not warranted. 3. By referring to the said reply, learned counsel for the petitioner submits that the impugned order is unsustainable. He submits that the respondents had a further four months in which to complete the assessment, whereas the impugned order was issued without waiting for the report of the valuation officer. As regards the 2nd and 3rd additions, he submits that the petitioner's reply was disregarded while confirming the additions. 4. Mrs.Premalatha, learned standing counsel for th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e of this fact, he proceeded to add the difference between the consideration specified in the sale deed and the guideline value as additional income and also initiated proceedings in respect of penalty. This approach is clearly unsustainable. 7. As regards the addition on account of rent receipts, the petitioner provided an explanation that rent was received towards a residential house property and that the income was duly disclosed. The petitioner further explained that tax had been wrongly deducted under Section 194IB instead of Section 194C of the Income-tax Act and that the petitioner should not be put to prejudice on that account. As regards the third addition, it was stated that the contractual receipt was Rs. 12,94,735/-, which ha ..... X X X X Extracts X X X X X X X X Extracts X X X X
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