ORDER

PER NARENDRA PRASAD SINHA, ACCOUNTANT MEMBER:

This appeal is filed by the Revenue against the order dated 06.03.2025 passed by the Commissioner of Income Tax (Appeals)-12, Ahmedabad (in short “CIT(A)”) for the Assessment Year (AY) 2020-21 in the proceedings under Section 153A read with Section 143 (3) of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’).

2. The brief facts of the case are that a search action under Section 132 of the Act was conducted in the case of the assessee as part of “Land Broker and Financer Group of cases” on 15.10.2019. From the documents seized from the residence of the assessee, vide Annexure-A/1 (Page nos.1 to 17), it transpired that the assessee had sold a land bearing Survey No.361 (Khata No.1156) admeasuring 15479 square meters, TPS No.204, FP No.247 admeasuring 9287 square meters along with his two brothers to one Shri Sandeep Narshinbhai Patel vide sale deed dated 19.09.2019 for a total sale consideration of Rs.20 Crores. The search was also conducted at the office premises of M/s. Dharnidhar Developers, in which the assessee was a partner, wherein certain digital data was found and seized vide page nos.01 to 211. At page no.145