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Order PER VIKRAM SINGH YADAV, A.M. : This is an appeal filed by the Assessee against the order of the Ld. CIT(A)/NFAC, Delhi dt. 06/12/2023 pertaining to Assessment Year 2012-13. 2. In the present appeal, the Assessee has raised the following grounds of appeal: 1. “That on the facts, circumstances and legal position of the case, Worthy CIT(A), NFAC in Appeal No. CIT (A), Chandigarh-2/10979/2019-20 has erred in passing order dtd. 06.12.2023 in contravention of provisions of S. 250 of the Income Tax Act, 1961 (hereinafter referred to as "Act").
2. That on facts, circumstances and legal position of the case, Worthy CIT(A) has erred in confirming the actions of Ld. AO in initiating, continuing and then concluding the impugned assessment u/s 148 r.w.s. 147 and hence the impugned assessment order deserves to be quashed.
3. That on facts, circumstances and legal position of the case, Worthy C1T(A) has erred in confirming addition of Rs. 2,19,50,000/- made by Ld. AO by erroneously holding the same as short term capital gain by assuming the amount of loan raised as purchase cost which is without due application of mind and more-so when amount as per registered purchase deed and legitimate expenses thereon should have been considered as purchase cost.
4. That on facts, circumstances and legal position of the case, the impugned order passed by the Ld. AO u/s 147 and then by Worthy CIT(A) u/s 250 deserves to be quashed since the same have been passed without affording reasonable opportunity of being heard to the appellant.
That the appellant craves leave for any addition, deletion or amendment in the grounds of appeal on or before the disposal of the same.”