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TMI Blog2022 (6) TMI 1247X X X X Extracts X X X X X X X X Extracts X X X X ..... ('the Act' hereinafter) dated 30/12/2016 for the Assessment Year (AY) 2013-14. 2. The appeal raises a single issue, i.e., deletion of the addition for Rs. 480.66 lacs made u/s. 69/69B of the Act by the Assessing Officer (AO) in assessment, by the ld. CIT(A) vide impugned order. 3. The assessee, a registered society since 19/11/1981, is in the business of acquisition of land for plotting and subsequent sale. On the basis of information gathered by the AO, the assessee had during the relevant year purchased four pieces of land for Rs. 747.35 lacs, as under: S.No. Date Amount (Rs.) 1. 18/04/2012 3,47,90,000 2. 18/04/2012 2,92,53,000 3. 19/07/2012 60,37,000 4. 07/11/2012 46,55,000 Total 7,47,35,000 The additions a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... d appeal. 4. We have heard the parties, and perused the material on record. 4.1 Our first observation in the matter is that there has been no admission of additional evidence by the first appellate authority, as the Revenue alleges per it's Ground 2, with Gd. 1 reiterating the AO's stand. As a reading of the assessment order itself shows, all the land purchase deeds as well as the accounts were before the AO, only with reference to which, regarding the variation between the sale (purchase) deeds and the accounts as not reconciled, he deemed the investment to that extent as unexplained. As explained by Shri Srivastava, the ld. counsel for the assessee, the entire record was produced before the AO, and the confusion has arisen because the p ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the four sale deeds (at PB-2, pgs. 1-46) clearly mentions of the entire sale consideration having been paid by that date, or otherwise any discrepancy observed by the AO that remains to be satisfactorily resolved, to no answer, even as the matter was kept part-heard twice 4.3 Further still, inasmuch as the land purchase details per the impugned order did not agree with that by the AO, the Bench made it a point to, during hearing, reconcile the two apparently different set of transactions, with a view to the confirm that the same are qua the same transactions, to find them as indeed so. The 'difference' in the dates between the two tables, i.e., by the AO and the ld. CIT(A), as we find, is on account of the fact that while the tabulation ..... X X X X Extracts X X X X X X X X Extracts X X X X
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