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2023 (2) TMI 421

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..... he DVO - HELD THAT:- We have gone through the report of the DVO as apparent the value determined by the DVO is again an estimate, inasmuch as he considered certain other properties at different rates and then averaged such rates to find out the value which the property ought to have realized on the transfer. It is vivid that the difference between the value declared by the assessee and the value d .....

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..... v Kabra For the Revenue : Shri Ramnath P Murkunde ORDER PER R.S. SYAL, VP : This appeal by the assessee is directed against the order dated 15.10.2022 passed by the National Faceless Appeal Centre (NFAC), Delhi confirming the imposition of penalty amounting to Rs.6,99,669 imposed by the Assessing Officer (AO) u/s 270A of the Income-tax Act, 1961 (hereinafter also called the A .....

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..... f the Act reducing the addition to Rs.7,05,000. The addition was computed by taking note of the value declared by the assessee at Rs.71,83,800 and the value determined by the DVO at Rs.78,88,800. On this basis, the AO rectified the original assessment and also imposed penalty u/s 270A of the Act at Rs.6,99,669. The ld. CIT(A) affirmed the penalty. Aggrieved thereby, the assessee has come up in app .....

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..... hat the difference between the value declared by the assessee and the value determined by the DVO is minimal and further the value of the DVO is on the basis of value of certain other nearby properties. 4. Section 270A of the Act provides for imposition of penalty for under-reporting and misreporting of income. Sub-section (2) enlists certain circumstances of under-reporting of income. Sub-sect .....

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