Smt. Sarita Satyendra Singh Vs ITO (ITAT Mumbai)
In this case before the Income Tax Appellate Tribunal, the assessee filed an appeal against the order dated 16-10-2025 passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre, for Assessment Year 2018–19.
The assessee had originally filed her return of income on 31-08-2018. The case was selected for scrutiny, and notices under Sections 143(2) and 142(1) were issued. However, there was no compliance by the assessee. A show cause notice dated 30-03-2021 was also issued, but again no response was filed. Consequently, the Assessing Officer proceeded to assess the income by bringing to tax a sum of ₹94,69,000, being the difference between the purchase consideration of three immovable properties and their stamp duty valuation, under Section 56(2)(x) of the Act.
The assessee challenged this before the appellate authority, but the Commissioner (Appeals) upheld the findings of the Assessing Officer, primarily noting lack of supporting evidence and confirming the addition.
During the hearing before the Tribunal, the assessee acknowledged non-compliance during assessment proceedings and attributed it to the Covid-19 pandemic. It was submitted that detailed written submissions had been filed before the Commissioner (Appeals). The assessee explained that one property was located in a remote village in Uttar Pradesh with issues such as water shortage, access problems, and disputes relating to title and ownership proportions, making stamp duty value an inappropriate measure of fair market value.
