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2025 (1) TMI 101

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..... cepted to be invested by her son Shri Gajanan Sudhir Hotkar, then no addition should be made; and secondly, as regards other property AO is directed to verify whether this property has been purchased from the funds / sources given by her son and if that is the case then, no addition should be made. For this limited purpose, the matter is restored back to the file of the ld. Jurisdictional AO (JAO) and assessee should comply with the notice and substantiate the source from her son for the purchase of second property for Rs. 30,00,000/-. Appeal of the assessee is partly allowed for statistical purposes. - Shri Amit Shukla, Judicial Member And Shri Girish Agrawal, Accountant Member For the Assessee : Shri Ashish A. Thakurdesai For the Revenu .....

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..... e above Grounds of Appeal. 3. The brief facts are that assessee is an individual who is a house-wife and has not filed any return of income as she does not have any kind of income. In this case, information was received on inside portal of Income Tax Department that income chargeable to tax has escaped assessment in the case of the assessee and accordingly, notice u/s. 148A (b) of the Act was issued. Since, there was no submission filed by the assessee, accordingly, notice u/s. 148 was issued on 31/03/2022 after obtaining the approval from ld. PCIT. As per the information, the assessee has made some unexplained investment for purchase of property of Rs. 1,18,66,200/- and accordingly, various notices were issued, however, assessee could not .....

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..... ed exparte, therefore, in the interest of justice, the matter is restored for the limited purpose that in so far as investment in one property for Rs. 1,02,66,200/- which has been accepted to be invested by her son Shri Gajanan Sudhir Hotkar, then no addition should be made; and secondly, as regards other property for sum of Rs. 30,00,000/-, the ld. AO is directed to verify whether this property has been purchased from the funds / sources given by her son and if that is the case then, no addition should be made. For this limited purpose, the matter is restored back to the file of the ld. Jurisdictional AO (JAO) and assessee should comply with the notice and substantiate the source from her son for the purchase of second property for Rs. 30, .....

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