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TMI Blog2024 (2) TMI 46X X X X Extracts X X X X X X X X Extracts X X X X ..... he assessee has challenged the addition /disallowance made u/s. 69C, 2(22)(e)and 56(2)(vii) of the Act in the assessment years 2011-12 to 2013-14 respectively. The assessee has also raised an additional ground in A.Y. 2013-14. As all these cases pertain to the same assessee, though on different grounds, we hereby pass a consolidated order. 3. We heard the parties and perused the record. We shall first take up the appeal relating to AY 2011-12. The issue contested in this appeal is related to the addition of Rs. 15.00 lakhs made by the AO, which related to advance received by the assessee from M/s Advance Technologies Ltd, which was considered by the AO as accommodation entry. We notice that the assessing officer has passed the assessment o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ssee submitted that the advance of Rs. 14.85 lakhs represented normal advance given to the employees and hence the provisions of sec. 2(22)(e) are not attracted. The assessee also submitted that she has resigned from the Board of the above said company and further does not hold substantial interest in the share capital of the company. Since the assessee did not furnish any evidence in support of the submissions made, the Ld CIT(A) confirmed the assessment made u/s 2(22)(e) of the Act. 5. We heard the parties on this issue and perused the record. We notice that the AO has invoked the provisions of sec. 2(22)(e) of the Act only for the reason that the assessee is a director in M/s Buddheshwar Estates P Ltd. However, we notice that the provis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n this year, the assessee is challenging the addition made u/s 56(2)(vii) of the Act. During the year relevant to AY 2013-14, the assessee has purchased a flat for Rs. 1.25 crores, whose stamp duty value was Rs. 1,50,22,500/-. Hence the AO added the difference amount of Rs. 25,22,500/- as deemed income u/s 50C of the Act. In the appellate proceedings, the assessee submitted that there are certain deficiencies in the property and hence she could purchase the property at a price lower than the stamp duty value. Accordingly, she pleaded that the issue of valuation of property may be referred to the Departmental Valuation Officer(DVO) as contemplated in sec. 50C of the Act. However, the Ld CIT(A) took support of valuation of flat in the same so ..... X X X X Extracts X X X X X X X X Extracts X X X X
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