SOPHIA MUSHTAQ PANIRWALA,G T ROAD MUMBAI vs. ACIT, ASSESSMENT UNIT ,NFAC
Before: SHRI AMIT SHUKLA & SHRI GIRISH AGRAWALAssessment Year: 2020-21
PER GIRISH AGRAWAL, ACCOUNTANT MEMBER:
This appeal filed by the assessee is against the order of National
Faceless
Appeal
Centre
(NFAC),
Delhi vide
Order
No.
ITBA/NFAC/S/250/2025-26/1080505962(1) dated 10.09.2025 passed against the assessment order u/s. 143(3) of the Income-tax Act, 1961
(hereinafter referred to as the “Act”), dated 13.08.2022 for AY 2020-21. 2. Grounds taken by the assessee are reproduced as under:
1. “Whether the Id CIT-A,NFAC was justified by passing the order without affording reasonable opportunity of being heard and personal hearing despite the admitted facts that there are so many glitches on portal resulting details/submissions couldn't be uploaded.
Whether the Ld CIT-A(NFAC) was justified by upholding the Assessment order on the issue of invoking section 56(2) on the difference of Rs.2,28,41,000/-due to stamp valuation and declared consideration without considering the nature
2
Sophia Mushtaq Panirwala
AY 2020-21
of property its location as the property whch may have to be transferred to,MCGM ,MUMBAI being situated in set back land.
Whether the Ld CIT-A(NFAC) was justified by upholding the Assessment order on the issue of unexplained investment in property of Rs.2,86,75,000/, despite the fact that all are very much explainable, by invoking section 69 read with section 115BBE without affording reasonable opportunity as the Appellant tried to upload but due to technical glitches could not be uploaded”
Brief facts of the case are that assessee filed her return of income on 09.01.2021 reporting total income at Rs.7,15,380/-. During the year under consideration, assessee had purchased an immovable commercial property jointly with her son having equal share at a total consideration of Rs.2,86,75,000/-. Sale deed was entered on 12.12.2019 and registered on the same date with Joint Sub-