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2024 Supreme(Online)(ITAT) 2657

INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
Vikram Singh Yadav, AM, Aakash Deep Jain, VP
BALWINDER SINGH BAJWA SANGRUR – Appellant
Versus
ITO WARD SUNAM – Respondent


Advocates:
For the Appellants/Petitioners:Shri Dev Ahuja, Advocate
For the Respondents: Smt. Amanpreet Kaur, Sr. DR

Table of Content
1. interpretation of cash deposits from agricultural land sale. (Para 2 , 3 , 5 , 6)
2. established nexus between sale proceeds and bank deposits. (Para 9 , 10)
3. decision to allow appeal based on established evidence. (Para 12 , 14)

आदशे/Order

PER VIKRAM SINGH YADAV, A.M. :

This is an appeal filed by the Assessee against the order of the Ld. CIT(A)/NFAC, dt. 30/03/2023 pertaining to Assessment Year 2011-12.

2. In the present appeal, the assessee has raised the following grounds of appeal:

“1. The Ld. CIT(A) was not right in sustaining the addition of Rs. 34,37,500/- u/s 69A of the Income Tax Act by not treating the entire cash receipt of Rs. 53,00,000/- as sale proceeds of agricultural land which is exempt from taxation.

2. The Ld. CIT(A) has erred in law and facts in not allowing to withdraw the Ground No. 2 that the AO has wrongly applied the provisions of section 144 of the Income Tax Act whereas the assessment has been completed u/s 143(3) r.w.s 147. The Ld. CIT(A) has also erred in law by wrongly justifying that order u/s 143(3) cannot be passed as notice u/s 143(2) was not issued on account of non-filing of return of income in response to notice u/s 148. However, me

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