MR AJAY SADASHIV BHAGAT,PUNE vs. ITO WARD-7(3) PUNE, PUNE
Income Tax Appellate Tribunal, PUNE BENCH “A”, PUNE
Before: SHRI R. K. PANDA & MS. ASTHA CHANDRAAssessment year : 2015-16
PER R.K. PANDA, VP:
This appeal filed by the assessee is directed against the order dated
05.09.2024 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2015-16. 2. Facts of the case, in brief, are that the assessee is an individual and has not filed his return of income for the impugned assessment year. On the basis of NMS
(Non-Filer Management Systems) information uploaded by the office of the DGIT
(Systems), it was noticed that the assessee during the F.Y. 2014-15 has made following transactions:
1. Salary of Rs.3,01,411/- received (TDS Form 26Q, Sec 192)
Purchased immovable property valued at Rs.15,48,75,869/-
Interest of Rs.13,130/- received whereon TDS u/s 194A is deducted
2
3. Since the assessee has not filed his return of income the veracity of the transactions could not be verified, the Assessing Officer, therefore, after recording reasons, reopened the assessment as per the provisions of section 147 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) and accordingly notice u/s 148 of the Act was issued on 26.03.2021. However, the assessee failed to file the return of income in response to the notice u/s 148 of the Act. Thereafter, statutory notice u/s 142(1) of the Act was issued on 28.10.2021 and again on 13.01.2022 was issued and served on the assessee which also remained un- complied with as per the Assessing Officer. The Assessing Officer, therefore, proceeded to complete the assessment as per the provisions of section 144 of the Act.
On perusal of information available with the department, the Assessing Officer noted that the assessee, during the year under consideration, has purchased immovable property amounting to Rs.15,48,75,869/- on various dates, the details of which are as under: S No Name of Purchaser Amount Date of transaction 1 Ajay Sadashiv Bhagat 9215500 20.09.2014 2 As above 11000000 03.11.2014 3 As above 28900000 10.07.2014 4 As above 14162500 17.12.2014 5 As above 9831250 17.12.2014 6 As above 43200000 12.04.2014 7 As above 9831250 25.11.2014 8 As above 28738369 04.10.2014 Total 154878869
3
5. He noted that as per information uploaded on Insight portal by the Joint Sub