KAMAL SINGH,INDORE vs. INCOME TAX OFFICER, INDORE

PER SIDDHARTHA NAUTIYAL - JM: The present appeal has been filed by the assessee against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (in short “NFAC”), Delhi vide order dated 17.01.2025 passed for A.Y. 2015-16. 2. The Assessee has raised the following grounds of appeal: “1. The Commissioner of Income Tax (Appeals) (CIT(A)) erred in confirming the assessment order passed u/s 147 r.w.s. 143(3) of the Income Tax Act, 1961 without affording proper opportunity of being heard to the appellant. 2. The CIT(A) erred in confirming the disallowance made by the assessing officer of Rs. 30,50,000/- under provisions of section 54f of the Act. 3. The CIT(A) erred in confirming the disallowance made by the assessing officer of Rs. 72,71,960/- under provisions of section 54b of the Act.” A.Y. 2015-16 3. The brief facts of the case are that the assessee, Shri Kamal Singh, is an individual who sold an immovable property during the Financial Year 2014–15 relevant to assessment year 2015–16 for a total consideration of ₹1,08,50,000/- but did not file his return of income within the time prescribed under section 139(1) of the Income-tax Act, 1961 (“the Act”). Based on information available with the Assessing Officer regarding the sale of the property, the assessment was reopened under section 147 of the Act. During the assessment proceedings, notices under sections 133(6) and 142(1) were issued. Information was called for from the purchaser of the property, the bank and the Sub-