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2024 Supreme(Online)(ITAT) 1083

INCOME TAX APPELLATE TRIBUNAL (KOLKATA BENCH)
SHRI SANJAY GARG, J, SHRI SANJAY AWASTHI, ACJ
TAMAL KUNDU KOLKATA – Appellant
Versus
A.C.I.T. CIRCLE - 37 KOLKATA – Respondent


Advocates:
For the Appellants/Petitioners: Shri Anup Sinha, AR
For the Respondents: Shri P.P. Barman, Addl. CIT

आदेश/ ORDER

Per Sanjay Garg, Judicial Member:

The present appeal has been preferred by the assessee against the order dated 2nd August, 2024 of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the ‘ld. CIT(A)’) passed u/s 250 of the Income Tax Act, 1961 (‘Act’).

2. The assessee has raised the following grounds of appeal:-

“1. That on the facts and circumstances of case and in law, the Ld. CIT(A) and the Ld. AO ought to have applied the provision of section 56(2)(x) of Income-tax Act, 1961 (hereinafter referred to as 'the Act') in respect of purchase of immovable property by the appellant in the previous year relevant to the assessment year 2017- 18 and not in the previous year relevant to assessment year 2018-19.

2. That on the facts and circumstances of case and in law, the orders passed by the Ld. CIT(A) and the Ld. AO are unsustainable and bad in law and hence, the same may kindly be struck down.

3. That on the facts and circumstances of case and in law, the Ld. CIT(A) erred in confirming the action of the Ld. AO in charging interest under section 234A and 234B of the Act.”

3. Apart from this, assessee has raised following additional grounds of appeal:-

“1. That

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