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2025 Supreme(Online)(ITAT) 3547

INCOME TAX APPELLATE TRIBUNAL (MUMBAI BENCH)
Shri Pawan Singh, J, Shri Prabhash Shankar, ACJ
Mrs. Roma Prakash Chhugani – Appellant
Versus
Income Tax Officer 24(3)(4) – Respondent


Advocates:
For the Appellants/Petitioners: Shri. Jagdish Shetty, CA
For the Respondents: Shri. Annavaram Kosuri, Sr. DR

Table of Content
1. grounds of appeal raised by the assessee. (Para 1)
2. background facts of the case. (Para 2 , 3)
3. cit(a)'s findings on additional evidence. (Para 4 , 5)
4. parties' arguments regarding the assessment. (Para 6 , 7)
5. court's analysis of evidence and reasoning. (Para 8 , 9 , 10)
6. final decision on the appeal. (Para 11)

PER PAWAN SINGH, JUDICIAL MEMBER:

1. This appeal by the assessee is directed against the order of Learned Commissioner of Income Tax (Ld. CIT(A)) dated 17.03.2025 for A.Y. 2011-12. The assessee has raised the following grounds of appeal:

“ 1. On the basis of facts and the circumstances of the case, the Hon’ble CIT(A) has grossly erred in confirming the addition made by the Lrnd. A.O. to the tune of Rs. 1,36,77,000/- u/s 69C of the I.T. Act 1961 towards purchase of Immovable property.

2. On the basis of facts and the circumstances of the case, the Hon’ble CIT(A) has grossly erred in upholding the rejection of additional evidence by the Lrnd A.O in his remand report who has hurriedly passed the remand order without considering /overlooking the detailed submissions made by the Appellant.

3. Hon’ble CIT(A) has grossly erred, on facts and in law, by rejecting

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