RAJNI ARVIND BIRLA,AHMEDABAD vs. THE ITO, WARD-3(1)(1), AHMEDABAD
Income Tax Appellate Tribunal, “B” BENCH, AHMEDABAD
Before: SHRI SANJAY GARG & SHRI MAKARAND V. MAHADEOKAR
PER MAKARAND V. MAHADEOKAR, ACCOUNTANTMEMBER:
This appeal by the assessee arises from the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal
Centre, Delhi [hereinafter referred to as “CIT(A)”], dated 10.03.2025, confirming the addition made by the Assessing Officer (AO) under section 50C of the Income-tax Act, 1961[hereinafter referred to as “the Act”], in the assessment framed under section 143(3) dated
28.09.2021 and subsequently rectified under section 154 on 20.11.2024. Rajni Arvind Birla Asst.Year 2018-19
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Facts of the Case
The assessee filed her return of income for the Assessment Year 2018–19 on 31.08.2018 declaring nil total income and showing a current year loss of Rs. 1,78,083/-. The case was selected for compulsory manual scrutiny on the basis of information available with the Department. A notice under section 143(2) of the Act was issued on 30.09.2019. 3. During the course of assessment proceedings, the Assessing Officer noticed that the assessee had on 26.12.2017, sold immovable property bearing Nos. 22, 24 and 26 on the ground floor of B Wing in the building known as “Gundecha Onclave” situated at Saki Village, Kherani Road, Mumbai – 400072 (“the subject property”). The sale consideration as per the registered sale deed was Rs. 1,75,00,000/-, which was duly reflected in the assessee’s return of income. The Sub-