RAMA SHANKER PAREEK,JAIPUR vs. INCOME TAX OFFICER, WARD NO. 7(2), JAIPUR
आयकर अपीलीय अधिकरण] जयपुर न्यायपीठ] जयपुर
IN THE INCOME TAX APPELLATE TRIBUNAL, JAIPUR BENCHES,”SMC” JAIPUR
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BEFORE: DR. S. SEETHALAKSHMI, JM & SHRI RATHOD KAMLESH JAYANTBHAI, AM vk;dj vihy la-@ITA. No. 253/JPR/2025
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PER: DR. S. SEETHALAKSHMI, J.M.
This is an appeal filed by the assessee against the order of ld. CIT(A),
National Faceless Appeal Centre (in short “NFAC”) Delhi dated 09.12.2024
passed under section 250 of the I.T. Act, 1961, for the assessment year 2010-11. The assessee has raised the following grounds of appeal :-
“1. The impugned order u/s 147 r.w.s.144 of the I. T. Act, 1961 dated 13.11.2017 as well as the action or proceedings u/s 147/144 are illegal, bad in law, barred by limitation, without juri iction, without approval/satisfaction from the proper or competent authority, against the principle of natural justice and various other reasons or and further contrary to the real facts of the case hence the same may kindly be quashed.
2
Rama Shanker Pareek, Jaipur.
The ld. CIT (A) has grossly erred in law as well as on the facts of the case in set- aside the assessment to AO for making a fresh assessment without deciding our legal grounds and other grounds of appeal when all the details were available before him. Hence the order of the ld. CIT (A) are bad in law, invalid, illegal and on facts of the case, for and various other reasons and hence the same may kindly be quashed.
Rs. 4,28,000/-: The ld. CIT (A) has grossly erred in law as well as on the facts of the case in confirming the addition of Rs. 4,28,000/- made by the ld. AO on account of cash deposits in the bank account as unexplained investment u/s 69C, also erred in not considering the material and details available on record in their true perspective and sense. Hence the addition so made by the ld. AO and confirmed by the ld. CIT (A) is also being contrary to the real facts of the case and not according to the provision of law, hence the same may kindly be deleted in full.
The ld. AO has grossly erred in law as well as on the facts of the case in charging interest u/s 234A,B&C. The appellant totally denies it liability of charging of any such interest. The interest, so charged, being contrary to the provisions of law and facts, may kindly be deleted in full.
That the appellant prays your honour indulgences to add, amend or alter of or any of the grounds of the appeal on or before the date of hearing.”
The brief facts of the case are that the assessee is a Government Ayurvedic Doctor and having income from salary and other sources. For the year under consideration, the assessee has filed his return of income on 27.07.2010 declaring the total income of Rs. 3,46,497/- after deduction under section 80C. On receipt of information from ITO (Hq.) vide his letter no. 657 dated 02.07.2015 (PB Pages 3- 4), the AO recorded reason on 27.03.2017 mentioning that “ As per information, the assessee has sold the plot no.72, Gayatri Nagar at Rs. 20,00,000/- on 04.11.2009 through the sale deed which was executed by the Sub-