PRADEEP KUMAR GUPTA,HAZARIBAG vs. DCIT/ACIT, CIRCLE -1, HAZARIBAGH

ITA 121/RAN/2026Status: DisposedITAT Ranchi11 August 2026AY 2014-156 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that since no addition was made in the case of a co-owner (Smt. Saroj Devi) based on a departmental valuation report which determined the fair market value at ₹29,20,000, there was no justification for sustaining the addition in the assessee's case.

What were the facts?

The assessee jointly purchased an immovable property with three other partners for ₹28,00,000, while the stamp valuation authority assessed it at ₹58,10,000. The Assessing Officer added the assessee's proportionate share of the difference as unexplained investment.

What were the issues?

Whether the addition of unexplained investment under Section 69 is justified when a co-owner's case with similar facts and valuation resulted in no addition. Whether the Assessing Officer correctly rejected the assessee's request for valuation under Section 50C.

Which sections of the Income-tax Act were involved?

Section 69,Section 50C,Section 133A,Section 131(1A),Section 148,Section 143(2),Section 142(1),Section 147,Section 250,Section 144B,Section 142(2A),Section 56(2)(x)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI RATNESH NANDAN SAHAY & SMT. RAJANI GUDURI

For Appellant: Shri Priyansh Anand, Adv
For Respondent: Shri Ram Chandra Marndi, Sr.DR
Hearing: 04/08/2026Pronounced: 11/08/2026

PER: RATNESH NANDAN SAHAY, A.M.

1.

This appeal by the assessee is directed against the order of the National Faceless Appeal Centre (NFAC), Delhi [in short, the ld. CIT(A)] dated 07/01/2026 for the Assessment Year (AY) 2014-15 wherein the assessee has raised following grounds of appeal:

"

1.

For that the learned officers below have erred in invoking the provisions of Section 69 when it is not a case of unexplained investment as the investment made in the property was duly reflected in the books of the appellant.

2.

For that the learned officers below have failed to follow the procedur

The order continues below.

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