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TMI Blog2025 (3) TMI 710X X X X Extracts X X X X X X X X Extracts X X X X ..... partment (in short, 'the A.O.') passed under section147 read with section 144Bof the Act, date of order 02/05/2023. 2. The assessee has taken the following grounds of appeal:- "1. On facts, in circumstances of the case and in law, the learned Commissioner of Income Tax- Appeals, National Faceless Appeal Centre ought to have held that reopening of assessment of the appellant is invalid in law. 2. On facts, in circumstances of the case and in law, the learned Commissioner of Income Tax - Appeals, National Faceless Appeal Centre ought to have held that since the impugned notices under section 148, 148A(b) & 148A(d) have been issues by Jurisdictional Assessing Officer, the subsequent assessment order passed by the Assessing Officer is null ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... registered at the same value, which was taken as the set forth value. However, the stamp duty valuation, as per the Stamp Duty Registration, amounted to Rs. 2,02,72,517/-, resulting in an addition of Rs. 97,72,517/- under Section 56(2)(vii)(b) of the Act. Aggrieved by this addition, the assessee filed an appeal before the Ld. CIT(A). The Ld. CIT(A), however, treated the assessee's allotment letter as a self-serving document and ultimately dismissed the appeal. Being dissatisfied with the order of the Ld. CIT(A), the assessee has now preferred the present appeal before us. 4. The Ld.AR argued and filed a written submission containing pages 1 to 124. The Ld.AR first invited our attention related to the letter of allotment by the promoter da ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ............ (b) Any immovable property,- (i) Without consideration, if the stamp duty value exceeds fifty thousand rupees, the stamp duty value of such property shall be considered. (ii) If acquired for consideration that is less than the stamp duty value by an amount exceeding fifty thousand rupees, the portion of the stamp duty value exceeding such consideration shall be considered. Provided that where the date of the agreement fixing the amount of consideration for the transfer of immovable property and the date of registration are not the same, the stamp duty value as on the date of the agreement may be taken for the purposes of this sub-clause: Provided further that this proviso shall apply only if the consideration, or part ..... X X X X Extracts X X X X X X X X Extracts X X X X
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