TMI Blog2022 (1) TMI 836X X X X Extracts X X X X X X X X Extracts X X X X ..... 10%, the same is ignorable and does not warrant any taxation. In this case, the Assessing Officer has passed the assessment order after due verification and consideration of detailed written submissions filed by the assessee against the show-cause notice and therefore, we are of the considered opinion that invoking the provisions of section 263 of the Act does not warrant for the reason that the assessment order passed by the Assessing Officer is neither erroneous nor prejudicial to the interest of the Revenue. Accordingly, we quash the revision order passed under section 263 of the Act by the ld. PCIT and allow the appeal of the assessee. - I.T.A. No. 481/Chny/2020 - - - Dated:- 11-1-2022 - V. Durga Rao, Member (J) And G. Manjunath ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on of ₹ 1,00,00,000/-. It was stated that the above amount represents the market value of the property and the assessee has not paid any amount more than the said consideration stated in the document. The Sub-Registrar, while valuing the property, has taken the current rate for the building and the land. The building was aged more than 29 years and the cost of such building would be very much less. The value adopted by the Sub-Registrar is on the higher side and requested the Assessing Officer to refer the matter to the Valuation Officer under section 50C(2) of the Act. The assessee has submitted that the State Government having considered the guideline value fixed for the land earlier would not represent the market value, which has r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the ld. DR dutifully relied on the order passed by the ld. PCIT. 6. We have heard both the sides, perused the materials available on record and gone through the orders of authorities below. We find that the Assessing Officer has examined the entire issue during the course of assessment proceedings. It is very clear from the assessment order itself. That apart, the Assessing Officer has issued a show-cause notice to the assessee and called for explanation. By considering the detailed explanation of the assessee, the Assessing Officer was of the opinion that where the difference between the actual value and market value is less than 10%, the same is ignorable and does not warrant any taxation. 6.1. In this case, the Assessing Officer h ..... X X X X Extracts X X X X X X X X Extracts X X X X
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