DILIP KUMAR SINGH AND SONS,PATNA vs. INCOME TAX OFFICER WARD 4(1), PATNA

The appeal of the assessee is allowed for statistical purposes

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishrai.T.A. No.312/Pat/2024 Assessment Year: 2015-16 Dilip Kumar Singh & Sons….. ……..……………………....Appellant C/O Dilip Kr. Singh, East Lohanipur, Pustakalaya Lane, Kadamkuan, Patna- 800003. [Pan: Aaihd8902J] Vs. Ito, Ward-4(1), Patna……. ….…….…............................…..…..... Respondent Appearances By: Shri D. V. Pathy, Advocate, Appeared On Behalf Of The Appellant. Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : December 17, 2024 Date Of Pronouncing The Order : December 19, 2024 आदेश / Order Per Sonjoy Sarma: The Present Appeal Has Been Preferred By The Assessee Against The Order Dated 01.02.2024 Of The National Faceless Appeal Centre [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’). 2. Brief Facts Of The Care Are That The Assessee Entered Into A Land Development Agreement With M/S Sankalp Construction During The Relevant Assessment Year. The Assessing Officer Noticed That As Per The Agreement, The Total Value Of Land Was Rs.4,41,14,025/- & The Value Of Share Owned By The Assessee At One Sixth Share Of 50% Of Land Owned By The Assessee Which Stands At Rs.36,76,169/-. On Perusal Of Records, The Assessing Officer Found That The Assessee Has Not Filed Any Return Of Income Nor Made Any Compliance, Therefore, He Issued Notice U/S 148

capital gains has escaped assessment. Accordingly, the Assessing Officer completed assessment assessing total income of Rs.36,76,169/- raising tax demand of Rs.12,94,968/- vide order dated 23.12.2019 u/s 144 r.w.s 147 of the Act. 4. Dissatisfied with the above order, the assessee preferred an appeal before the ld. CIT(A) against the assessment order challenging the validity