HIREN RAMESHBHAI PATEL,AHMEDABAD vs. THE DY.CIT, CIRCLE-3(2), AHMEDABAD

In law and in facts and circumstances of the appellant's case, the Ld CIT(A) has erred in upholding the impugned addition on account of section 56(2)(vii) (b) amounting Rs. 90,00,000/-, Assessment Year 2016-17

1 Without prejudice to above, the appellant submits that the Ld CIT(A) has erred in upholding addition of Rs. 90,00,000/- without allowing actual cost incurred by appellant for purchase of land in question amounting to Rs. 8,16,458/-.

In law and in facts and circumstances of the appellant's case, the Ld. CIT(A) has erred in upholding the impugned addition u/s 68 amounting Rs. 4,97,543/- received as refund for surrender of Life Insurance Policy offered as exempt income by the appellant.

1 Without prejudice to above, the appellant submits that the Ld CIT(A) has erred in upholding addition of Rs. 4,97,543/- without allowing of insurance premium paid by the appellant towards the Life Insurance Policy.

The appellant craves leave to add, alter or amend and/or withdraw any ground or grounds of appeal either before or during the course of hearing of the appeal.”

The return of income was filed by the assessee for assessment year 2016-17 on 29-03-2018 declaring total income at Rs. 54,59,950/-. The case was selected for complete scrutiny under CASS and the notice u/s. 143(2) of the Income Tax Act, 1961 was issued on 28-09-2018 which was duly served upon the assessee. Subsequently, statutory notices were issued to the assessee which were responded by the assessee during the assessment proceedings. The Assessing Officer observed that the assessee made an agreement to sale in the year 1992-93 for acquiring a land as an owner of plot along with other co-owners. The purchase deed of the said land was not registered at that time as the title of the land could not be received in the hands of the Lalchand Cooperative Society due to some objections. Hence, the registration of sale deed could not be I.T.A No. 681/Ahd/2024