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2019 (10) TMI 600 - AT - Income TaxValidity of notice u/s 148 - assessment of unexplained source of deposits in Canara Bank - HELD THAT:- No new issue has cropped up, subsequently on new set of facts. The reason forming belief was deposit of ₹ 31.00 lakhs which was sourced from the sale of land which attracts the capital gains tax and the assessee did not offer the same for taxation. Thus the issue for reopening and addition made is one and the same. we hold that the AO has rightly issued notice u/s 148, accordingly, we uphold the order of the Ld.CIT(A) and dismiss the appeal of the assessee on this ground. Merits of the case, the Ld.CIT(A) found that the impugned land was sold for non agricultural purpose and admitted that the said land is situated within the limits of GVMC. Therefore, the Ld.CIT(A) held that the sale consideration attracts capital gains tax and accordingly upheld the order of the AO. During the appeal hearing, the Ld.AR did not advance any arguments on merits of the case. Since the said land is within the limits of GVMC and the land was sold for non agricultural purposes to non agriculturists, we uphold the order of the Ld.CIT(A) and dismiss the appeal of the assessee. The appeal of the assessee is dismissed.
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