Bench: Shri Yogesh Kumar U.S & Shri Manish Agarwal[Through Virtual Mode] [Assessment Year : 2023-24] Pradeep Kumar Walia Vs Dcit C/O-Matta Garg & Co. Central Circle 15, Astley Hall Dehradun Dehradun, Uttarakhand Uttarakhand-248001 Pan-Aabpw2423F Appellant Respondent Assessee By Shri S.K.Matta, Ca Revenue By Ms. Poonam Sharma, Cit Dr Date Of Hearing 10.12.2025 Date Of Pronouncement 18.02.2026 Order Per Manish Agarwal, Am : The Present Appeal Is Filed By The Assessee Against The Order Dated 31.07.2025 By Ld. Commissioner Of Income Tax (A)-3, Noida [“Ld.Cit(A)”] In Appeal No. Cit(Appeals) Noida-3/10009/2022-23 Passed U/S 250 Of The Income Tax Act, 1961 [“The Act”] Arising From The Assessment Order Dated 07.02.2025 Passed U/S 143(3) Of The Act Pertaining To Assessment Year 2023-24. 2. Brief Facts Of The Case Are That The Assessee Is An Individual & Filed His Return Of Income U/S 139(4) Of The Act On 04.11.2023, Declaring Total Income Of Inr 86,20,630/-. The Case Of The Assessee Was Selected For Scrutiny Under Cass For The Reason That The Assessee Has Claimed Deduction U/S 54F Of The Act & Corresponding Capital Gain Was Not Declared In The Return Of Income Filed By The Assessee.

capital gain was not declared in the return of income filed by the assessee. 3. In the assessment order, AO observed that a search and survey action was carried out at the business premises of M/s. Mehta Brothers & Others Group of cases on 24.11.2022 and the resident of Shri Raj Lumba was also covered. During the course of search, certain