Gurudev Chandrashekhar Karanth Vs Income Tax Department (ITAT Pune)
The ITAT Pune considered an appeal filed by Gurudev Chandrashekhar Karanth against the assessment order passed under Section 147 read with Section 144C(13) of the Income Tax Act, 1961 for AY 2018-19. The assessment order dated 23 December 2024 emanated from the Dispute Resolution Panel’s directions dated 20 December 2024. The dispute concerned an addition of Rs.7,75,500 under Section 56(2)(x) in respect of the purchase of an immovable property.
The assessee was residing in California, United States of America during the relevant year and had stayed in India for 21 days during FY 2017-18. The Tribunal recorded that he was a Non-Resident for AY 2018-19. He had purchased, jointly with his wife Smt. Isha Bhatt, Flat No. 4101, Building Alpine, Thakur Village Road, Phase-1, Samata Nagar, Kandivali, Mumbai, which was registered on 9 January 2018. The purchase consideration was Rs.1,82,91,500, while the Stamp Authority valued the property at Rs.2,11,35,810.
The assessee had not filed a return under Section 139, following which the Assessing Officer issued notice under Section 148A(b). After the assessee failed to comply, an order under Section 148A(d) was passed and notice under Section 148 was issued on 28 April 2022. The assessee subsequently filed a return declaring NIL income and responded to notices issued under Sections 143(2) and 142.
