DVO Reference Based on Wrong Facts; Only 1.71% Difference Leads to 153A Assessment Quashed

Parveen Gupta Vs ACIT (ITAT Delhi) DVO reference held factually wrong; variation only 1.71%; AO & JCIT found non-applicative of mind; 153A assessment quashed; addition u/s 69 deleted in full These two connected appeals concerned co-owners Parveen Gupta & Gautam Gupta, who jointly purchased a residential property (BP-22, West Patel Nagar, New Delhi) for ₹9.90 crore vide sale deed dated 12.09.2019, each having 50% share. Circle rate value, as shown in page 1 & page 4 images of the file, was ₹9,70,06,834/-, meaning the property was purchased above stamp-duty value. Assessment u/s ...