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TMI Blog2020 (4) TMI 556X X X X Extracts X X X X X X X X Extracts X X X X ..... o condone the delay. After hearing both the parties, we condone the delay and admit the appeal of the assessee. 2. All the grounds of appeal are related to the addition of Rs. 24,77,367/- u/s 69B of the Income Tax Act, 1961 (in short 'Act'). During the assessment proceedings, the Assessing Officer (AO) found that the assessee has purchased the property in Narsaraopet town old survey No.464, T.S.No.743, Guntur District admeasuring Ac.2.45cts or 11,858 sq.yds of land for a consideration of Rs. 45,50,000/- along with Sri Velagapudi Vasudeva Rao on 15.06.2012 vide document No.9571/2012 on 15th June 2012. During the assessment proceedings, the AO called for the details, but the assessee failed to furnish the details. Therefore, the AO treated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... was unregistered and the stamp paper was purchased on 24.03.2005. Since the property was registered on 15.06.2012 and the Registered sale deed do not support the purported agreement dated 31.12.2010, the agreement dated 31.12.2010 appears to be an afterthought hence, rejected. On perusal of the sale deed, there was no mention with regard to shares of the parties. Therefore, we hold that the lower authorities rightly assessed 50% of the share of the property in the hands of the assessee. Accordingly, appeal of the assessee on this ground is dismissed. 5. The next ground is related to the taxing share of 50% u/s 69B of the Act. During the appeal proceedings, the Ld.AR submitted that as per the sale deed dated 15.06.2012, the payments were ma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the schedule given above and out of which only sum of Rs. 5.50 lakhs was paid in the impugned assessment year. Apart from sum of Rs. 5,50,000/- stamp duty of Rs. 21.09 lakhs was also incurred in the relevant A.Y.2013-14. Therefore, 50% of the consideration paid during the impugned assessment year amounting to Rs. 13.295 lakhs required to be brought to tax in the A.Y.2013-14 as per section 69B of the Act. As per section 69B, where in any financial year, the assessee is found to be the owner of any money, bullion, jewellery or other valuable articles or the investment made recorded in the books of accounts but offers no explanation, required to be taxed. From the perusal of the sale deed, the assessee has made the investment to the extent of ..... X X X X Extracts X X X X X X X X Extracts X X X X
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