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2010 (3) TMI 838 - ITAT, AHMEDABADBlock Assessment - Purchase of flat - source of income - receipt of on-money by the developers - The assessee in his initial reply admitted before the Assessing Officer that the flat in question has been purchased by him in his name for a sum of Rs. 3,73,000. However, the seized material proves that it was purchased for a sum of Rs. 6,21,000. The amount of Rs. 3,73,000, according to the assessee was paid by cheque. The builders in their statements have admitted to have received on-money from purchasers for sale of the flats. The seized material is, therefore, supported by the statements of the builders. Ultimately, when the assessee was confronted with the seized material, he has changed his version and explained that remaining amount of Rs. 2,48,000 has been paid by him out of Rs. 2,50,000 contributed by his father. - Held that:- the authorities below were justified in holding that the assessee has failed to explain the source of investment in the flat in a sum of Rs. 2,48,000. Considering the facts and circumstances noted above, and the facts that no entry is also recorded in the account of the assessee in respect of the amount contributed by the assessee's father - Decided against the assesssee. Additional evidence - Held that:- since the assessee has not raised this ground either before the Assessing Officer or before the learned Commissioner of Income-tax (Appeals) and no specific ground is taken in the grounds of appeal before the Tribunal, therefore, submission of the assessee may not be entertained which also requires verification of facts. - request for additional ground rejected.
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