DCIT Vs Jaswinder Kaur Grewal (ITAT Chandigarh)
Extrapolated SCO Value Rejected Again: ITAT Chandigarh Upholds Deletion of ₹77.27 Lakh; When Seller’s Case Fails, Buyer’s Addition Can’t Stand:
The Chandigarh Bench “A” of the ITAT, vide order dated 30.12.2025 in DCIT, Central Circle-1, Ludhiana v. Jaswinder Kaur Grewal (ITA No.200/Chd/2025, AY 2022-23), dismissed the Revenue’s appeal and upheld deletion of ₹77,27,500 added u/s 69B r.w.s. 115BBE on account of alleged unexplained investment in purchase of a Shop-cum-Office (SCO).
The assessee had purchased SCO No.3 measuring 144.44 sq. yards from M/s Homelife Buildcon Pvt. Ltd. for a registered consideration of ₹22 lakh. Based on search findings in the seller’s case, the AO adopted an extrapolated sale value of ₹99,27,500 (as determined in Homelife Buildcon’s assessment) and treated the differential amount as unexplained investment in the hands of the purchaser.
The CIT(A) deleted the addition by following his own order in the case of M/s Homelife Buildcon Pvt. Ltd., wherein the very basis of extrapolation of SCO rates had been rejected. Before the Tribunal, it was demonstrated that the issue had already attained finality, as the ITAT had confirmed deletion of similar additions in Homelife Buildcon’s case (ITA Nos. 880 & 1036/Chd/2024) and in the purchaser’s case of Sh. Balwinder Singh (ITA No.188/Chd/2025).
The Tribunal held that once the addition based on extrapolated value did not survive in the hands of the seller, a derivative addition in the hands of the buyer on identical facts could not be sustained. In absence of any independent incriminating material evidencing on-money payment by the assessee, the Revenue’s appeal was found to be devoid of merit.
Accordingly, the ITAT dismissed the Revenue’s appeal and confirmed deletion of the addition in entirety
FULL TEXT OF THE ORDER OF ITAT CHANDIGARH
