JAGDISH KISHIN RANEY,MUMBAI vs. INCOME TAX OFFICER (IT)-4(1)(1), MUMBAI

Appellant /Assessee by : Shri Vimal Punamya, AR : Shri Surendra Meena, Sr. DR Revenue / Respondent by Date of Hearing : 27.01.2025 Date of Pronouncement : 04.02.2025 O R D E R

Per Padmavathy S, AM:

Jagdish Kishin Raney 2. The assessee is a non-resident individual and did not file the return of income for the AY 2014-15. The Assessing Officer (AO) based on NMS data noticed that the assessee has purchased immovable property for a consideration of Rs. 3,60,00,000/-. Since the assessee has not filed the return of income the AO issued a notice under section 148 reopening the assessment. In response the assessee neither filed the return of income nor filed any response. Accordingly, the AO completed the assessment under section 147 r.w.s. 144 of the Act in which he treated the entire amount of Rs. 3,60,00,000/- as unexplained investment under section 69A of the Act. Aggrieved assessee filed further appeal before the CIT(A). Before the CIT(A), the assessee submitted additional evidences explaining the source and the fact that the property was purchased by the sister of the assessee who funded the entire cost. The CIT(A) after calling for the remand report from the AO gave partial relief to the assessee and sustained the addition to the extent of Rs. 10,00,000/-. The assessee filed further appeal before the Tribunal against the order of the CIT(A).