आदेश/ORDER 

Per Avdhesh Kumar Mishra, AM:

This appeal for Assessment Year (‘AY’) 2018-19 filed by the assessee is directed against the order, dated 08.03.2025, passed under section 263 of the Income Tax Act, 1961 (‘Act’) by the Principal Commissioner of Income Tax (Central), Bhopal [‘PCIT(C)’]. Further, the assessee has also file a Stay Application (‘SA’) with request to stay the consequential assessment proceedings initiated in pursuance of the order passed under section 263 of the Act by the Ld. PCIT(C).

2. The appellant assessee vide sole ground, read as “The order passed by the PCIT is bad in law, passed without satisfying the conditions mentioned in explanation 2 of the sec 263”, has challenged the validity of the impugned order.

3. The relevant facts giving rise to this appeal are that the appellant assessee filed his original Income Tax Return (‘ITR’) of the relevant year on 29.12.2018 declaring income of Rs.7,95,750/-. The assessee had bought a property; i.e. the land admeasuring 0.405 Hectare having Khasra No.1291/2 Sakti Tehsil for Rs.18,00,000/-; however, he had paid stamp duty on the market value of Rs.46,33,000/- the said property determined by the Stamp Valuation Authorit