OMNIBUS HEALTHCARE INDIA PVT. LTD.,,MEERUT vs. DCIT, CIRCLE-1(1)(1), MEERUT

This assessee’s appeal for assessment year 2017-18, arises against the Commissioner of Income Tax (Appeals)-National Faceless Appeal Centre [in short, the “CIT(A)-NFAC”], Delhi’s DIN and order no. ITBA/NFAC/S/250/2023-24/1059017134(1), dated 22.12.2023 involving proceedings under section 143(3) of the Income-tax Act, 1961 (hereinafter referred to as ‘the Act’).

Heard both the parties at length. Case file perused.

Learned counsel representing assessee, submits that the sole substantive issue, which arises for our adjudication is that our correctness of section 69 unexplained investment addition made by the Assessing Officer to the tune of Rs.6,61,86,825/- representing investment made in construction of a commercial property situated at Ansal Town, village Jitaoli, Pargana, Daurala, Tehsil Sardana, District Meerut, Uttar Pradesh for the period from 01.04.2014 to 31.03.2017 4. It emerges from a perusal of the assessment discussion at page 4 that the assessee had admitted his foregoing cost of construction Rs.44,44,745/- as against that estimated by the Valuation Officer, Meerut to the tune of Rs.2,05,83,500/- pertaining to financial year 2016-17 for assessment year 2017-18. The CIT(A)’s detailed discussion in para 7 page 94 in turn has restricted the said valuation from Rs.2,05,83,500/- to Rs.1,30,90,027/- only which leaves the assessee aggrieved. 5. It is in this factual backdrop that the learned counsel representing assessee has raised his twin arguments that the impugned valuation itself is based on CPWD than State’s PWD rates and both the lower authorities have nowhere granted