O R D E R

Per Rahul Chaudhary, Judicial Member:

1. The present appeal preferred by the Assessee is directed against the Order, dated 04/11/2025, passed by the National Faceless Appeal Centre (NFAC), Delhi [hereinafter referred to as the ‘CIT(A)’] whereby Learned CIT(A) had dismissed the appeal against the Assessment Order, dated 30/03/2021, passed under Section 143(3) read with sections 143(3A) & 143(3B) of the Income Tax Act, 1961 [hereinafter referred to as ‘the Act’], for the Assessment Year 2018-2019.

2. The Assessee has raised following grounds of appeal:

“A. General

1. On the facts and circumstances of the case and in law, the Ld. Commissioner of Income-tax (Appeals) [‘CIT(A)’] has erred in confirming the action of the Ld. Assessing Officer (‘AO’) of assessing the total income of the Appellant at Rs.55,08,460/- as against returned income of Rs. 4,46,000/- for AY 2018-19.

B. Natural Justice violated

2. On the facts and circumstances of the case and in law, the Ld. CIT(A) as well as the Ld. AO, erred in not granting sufficient opportunity to present the case and thus principles of natural justice are grossly violated.

C. On Merits – Addition u/s 50C

3. On the facts and circumstances of the case and in law, the Ld. CIT(A) has erred in upholding the addition of Rs.50,62,460/- to the returned income of the Appellant by invoking the provisions of section 50C of the Income-tax Act, 1961(‘Act’).

4. On the facts and circumstances of the case and in law, the learned CIT(A) has failed to appreciate that the stamp duty valuation relates to residential and commercial ready properties, whereas the property sold by the appellant during the captioned AY was a garage and accordingly an appropriate adjustment for the same ought to have been given to the ready reckoner value as per the Stamp Valuation authority.

5. Without prejudice to the above Ld. CIT(A) as well as Ld. AO, erred in not referring to a Valuation officer for determination of the fair market value of the property, as mandated u/s 50C(2)&(3) of the Act.

D. Levy of interest u/s 234B and 234C

6. On facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming the action of the Ld. AO of levying interest u/s 234B and 234C of the Act.

E. Initiation of penalty u/s 270A

7. On facts and circumstances of the case and in law, the Ld. CIT(A) has erred in confirming the action of the Ld. AO of initiating penalty proceedings under section 270A of the Act.

The Appellant craves leave to add, amend, delete, vary, omit or substitute any of the aforesaid grounds of appeal at any time before or at the time of hearing of appeal, so as to enable the Hon’ble Income-tax Appellate Tribunal to decide this appeal according to law.”

3. The relevant facts in brief are that the assessment under Section 143(3) read with sections 143(3A) & 143(3B) of the Act was framed on the Assessee for the Assessment Year 2018-2019 vide Assessment Order, dated 30/03/2021. The Assessing Officer assessed the income of the Assessee at INR.55,08,460/- after making an addition of INR.50,62,460/- under Section 50C of the Act and bringing the same to tax in the hands of the Assessee as Long Term Capital Gains.

4. Being aggrieved, the Assessee has preferred the appeal before the Learned CIT(A). It was contended on behalf of the Assessee that during the relevant previous year the Assessee had sold a garage which was received as a gift from his father. During the assessment proceedings the Assessee had explained that the aforesaid garage was sold for a consideration of INR.25,00,000/-. The Assessee also placed before the Assessing Officer a Valuation Report, dated 10/02/2021, wherein the market value of the aforesaid garage was ascertained at INR.10,80,600/-. However, the Assessing Officer rejected the aforesaid valuation report and the registered consideration of INR.25,00,000/-. Without making reference to District Valuation Officer (DVO), the Assessing Officer adopted stamp value of INR.61,65,000/- as