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TMI Blog2024 (12) TMI 1108X X X X Extracts X X X X X X X X Extracts X X X X ..... essee as well as the statement showing remittance from USA and Canada including that of confirmation affidavit, bank statement, PAN card details and passport details of all these parties. These aspects were not taken into account by the AO as well as by the CIT(A). Hence, the addition made is not justifiable. Thus, appeal of the assessee is allowed. - Dr. Brr Kumar, Vice President And Ms. Suchit ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t year 2012-13 on 27.03.2014 declaring total income at Rs. 15,59,380/-. The return was processed under Section 143(1) of the Income Tax Act, 1961 and later on Section 147 of the Act was initiated after recording the reasons. Notice under Section 148 of the Act dated 25.03.2015 was issued and served upon the assessee. The assessee replied and submitted that return filed under Section 143(1) of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ty of Rs. 7,55,000/- as well as Registration Charges of Rs. 1,54,390/-. Thus, the Assessing Officer observed that the cost of purchase of the of said land works out to Rs. Rs.2,67,94,230/-. After going through the assessee s reply, the Assessing Officer observed that the assessee has suppressed gain of Rs. 1,88,429/- as the assessee has not explained as to how he has claimed his share of 22% in pl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1,88,429/- is not pressed. As regards ground no.1(b) relating to addition of Rs. 59,28,094/- as unexplained unsecured loans under Section 68 of the Act, the Ld. AR submitted that the assessee has given the trial money trade in from the four parties that are Son of the assessee i.e. Ketul Yashwantbhai Patel Daughter of the assessee i.e. Kinnari Amit Patel, Daughter-in-law of the assessee i.e. Bind ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ves of the assessee as well as the statement showing remittance from USA and Canada including that of confirmation affidavit, bank statement, PAN card details and passport details of all these parties. These aspects were not taken into account by the Assessing Officer as well as by the CIT(A). Hence, the addition made by the Assessing Officer is not justifiable. Thus, appeal of the assessee is all ..... X X X X Extracts X X X X X X X X Extracts X X X X
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