O R D E R

PER R.K. PANDA, VP:

This appeal filed by the Revenue is directed against the order dated 08.10.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2023-24.

Facts of the case, in brief, are that the assessee is an individual and has filed his return of income u/s 139 of the Income Tax Act, 1961 (hereinafter referred to as ‘the Act’) for the impugned assessment year declaring total income of Rs.98,53,380/-. The case was selected for scrutiny under CASS on the ground that the sale consideration of the property reported in ITR is less than the sale consideration of property reported in SFT. Accordingly, the Assessing Officer issued statutory notice u/s 143(2) of the Act and thereafter notice u/s 142(1) of the Act along with a questionnaire were issued and served on the assessee in response to which the assessee filed his response.

During the course of assessment proceedings the Assessing Officer noted that the assessee has received an amount of Rs.33,00,00,000/- as sale consideration for immovable property. The value of the property as per the stamp valuation authority was declared at Rs.15,18,86,616/-. He noted that the assessee has claimed deduction under secti