M/S SILVER OAKS TOWNSHIP LTD.,BATHINDA vs. DCIT, CC-III, LUDHIANA
आयकर अपीलȣय अͬधकरण,चÖडीगढ़ Ûयायपीठ, चÖडीगढ़
IN THE INCOME TAX APPELLATE TRIBUNAL
CHANDIGARH BENCH, ‘B’, CHANDIGARH
BEFORE SHRI MAHAVIR SINGH, VICE PRESIDENT &
SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER
आयकर अपील सं./ ITA No. 939/CHD/2018
Ǔनधा[रण वष[ / Assessment Year : 2012-13
M/s Silver Oaks Township
Ltd., #3400-B,
Street No. 6/1, Power House
Road,
Bhatinda
Vs.
बनाम
The DCIT,
Central Circle-III,
Ludhiana
èथायी लेखा सं./PAN No: AAJCS3445B
अपीलाथȸ/ APPELLANT
Ĥ×यथȸ/ REPSONDENT
( PHYSICAL HEARING )
Ǔनधा[ǐरती कȧ ओर से/Assessee by : Shri Sudhir Sehgal, Adv.
राजèव कȧ ओर से/ Revenue by : Dr. Ranjit Kaur, Addl. CIT, Sr. DR
सुनवाई कȧ तारȣख/Date of Hearing
:
02.01.2025
उदघोषणा कȧ तारȣख/Date of Pronouncement
:
03.02.2025
आदेश/Order
Per Krinwant Sahay, A.M.:
Appeal in this case has been filed by the Assessee against the order of the ld. CIT(A-5,) Ludhiana dated
11.04.2018 for assessment year 2012-13. 2. Grounds of appeals are as under:-
939-Chd-2018
M/s Silver Oaks Township Ltd, Bhatinda
That Ld. CIT(A) erred on facts and law in confirming the action of the AO of assessing the income of the assessee at Rs. 43,25,1007- as against income declared at Rs. 18,49,600/- in the return of income. 2. That the Worthy Commissioner of Income Tax (Appeals)-5, Ludhiana has erred in confirming the addition of Rs. 23,92,500/- u/s 40A(3) of the Income Tax Act, 1961 by making cash payment to the sellers on account of purchase of land. 3. That Ld. CIT(A) erred on facts and law in confirming the addition made by the AO by invoking the provisions of section 40A(3) as the assessee made cash payments exceeding Rs. 20,000/- for purchase of land held as stock in trade. The explanation furnished by the assessee, based on facts and case laws, during the course of appellate proceedings has not been rebutted by the Ld. CIT(A). 4. That Ld. CIT(A) erred on facts and law in confirming the disallowance of Rs. 83,000/- made by the AO on account of preoperative expenses being fee paid to