SHARVAN KUMAR,KALANAUR vs. ITO, WARD 4, ROHTAK

PER YOGESH KUMAR, U.S. JM: The present appeal is filed by the Assessee against the order of the Commissioner of Income Tax (Appeal)/National Faceless Appeal Centre [‘NFAC’ for short] dated 26/02/2024 for the Assessment Year 2011-12. 2. The grounds of Appeal are as under:- “1. That the order of the Ld. CIT (Appeals) is against law and facts. 2. That the Ld. CIT (Appeals) erred in confirming the action of Ld. AO is issuing notice u/s 148, although the notice issued was invalid, illegal and without juri iction.

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3 That the Ld. CIT (Appeals) erred in not giving a copy of reasons recorded u/s 148 to the appellant inspite of specific request by the appellant to the CIT (Appeals) in this regard.
4. That the Ld. CIT (Appeals) erred in not considering the reply and arguments taken by the appellant and erred in passing a non-speaking order.
5. That the Ld. CIT (Appeals) erred in confirming the addition of Rs. 1,00,00,000/- made by the Ld. AO by treating the cost of agricultural land purchased by the appellant at Rs.
1,03,28,400/-, although the appellant had purchased the land for only Rs. 40,80,000/-.
6. That the Ld. CIT (Appeals) erred in not accepting the source of land purchased of Rs. 40,,80,000/-, although the appellant had filed all the details & documents before the Ld.
AO as well as before Ld. CIT (Appeals)
7. That the Ld. CIT (Appeals) as well as Ld. AO erred in not referring the matter to valuation cell inspite of specific claim by the appellant that the market rate of the property purchased was much less than the circle rate of property
8. That the Ld. CIT (Appeals) erred in confirming the action of Ld. AO in making addition of Rs. 1,00,00,000/-, although
Ld. AO vide his Show Cause Notice dt. 06.12.2018 had show caused appellant for total addition of only Rs. 40,60,900/-, but actually made addition of Rs. 1,06,22,100/- while passing assessment order.
9. That the Ld. CIT (Appeals) erred in confirming the addition of Rs. 1,00,000/-out of total addition of Rs. 6,22,100/- made by the Ld. AO by treating the agriculture income of the appellant as income from other sources.
10. That the Ld. CIT (Appeals) erred in not giving relief of returned income and of the income of Rs. 1,00,000/- treated as income from other sources, out of addition made of Rs.
1,00,00,000/- on account of property purchased by the appellant.
11. That the Ld. CIT (Appeals) erred in not confronting to the appellant the remand report submitted by the Ld. AO during

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13. That the appellant craves leave to add, alter, armend, modify or withdraw any of the ground of appeal at the time of hearing.”
3. Brief facts of the case are that, the Assessee purchased an agriculture land measuring 47Kanal 12 Marla in village Anwal, District
Rohtak vide sale deed dated 08/04/2010, registered as Document No. 4
in the Office of the Sub-