NIVRUTI MAHADEV GHADGE,MUMBAI vs. INCOME TAX OFFICER WARD 22(2)(1), MUMBAI

PER BEENA PILLAI, JM Present appeals filed by the assessee is against order dated 27/12/2023 passed by NFA Delhi for assessment year 2018-19 on following grounds of appeal: 1. The assessment order dated 07.04.2021 is bad in law and without juri iction as the same has been passed under section which were no longer applicable. 2. The Ld. CIT(A) has erred in confirming the addition made by the Ld. AO of Rs. 39,45,128/- u/s 56(2)(x) of the Act.

Nivruti Mahadev Ghadge
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3. The order passed by the Ld. CIT(A) and the Ld. AO are without considering the detailed submissions filed and the documentary evidences relied upon and therefore, both the orders are bad in law and liable to be set aside.
4. The Ld. AO erred in initiating penalty proceeding u/s 274 r.w.s
270A of the Act, vide letter dated 07.04.2021. 5. The Ld. AO, has erred in the levying interest under section 234B of the Act.

Brief facts of the case are as under:
2. The assessee is an individual and proprietor of M/s. Naveen
Enterprises. He filed his return of income on 30/08/2080 declaring total income of ₹5,44,170/- for the year under consideration. The return was processed under section 143 (1) of the act and was selected for scrutiny. The Ld.AR accordingly issued notice under section 143 (2) and 142 (1) of the act calling upon assessee to furnish various details.
2.1 The Ld. AO observed that, assessee during the year under consideration purchased immovable property for consideration of ₹7,50,000/-. Subsequently, the said property was registered with the sub-