Shriram Sahadev Rawool Vs ITO (ITAT Pune)
Assessee did not file return for AY 2013-14. AIS information showed sale of immovable properties valued at Rs.2,94,57,000 in FY 2012-13. AO issued notice u/s 148 dated 25.02.2020, followed by 142(1) notices, all of which remained un-complied. AO therefore treated Rs.2,92,57,000 as LTCG taxable u/s 112, adopting full sale consideration in absence of details.
Before CIT(A)/NFAC, Assessee submitted documents claiming land was rural agricultural land & hence not a capital asset u/s 2(14). CIT(A)/NFAC rejected this, holding that documents showed land to be non-agricultural, & further no evidence of agricultural activity was produced. CIT(A) also highlighted that a price jump from purchase in 2008 to sale at Rs.2.94 crore in 2012 made the claim of agricultural use implausible.
Before Tribunal, Assessee remained absent. Tribunal noted that Assessee failed to furnish any material to contradict CIT(A)’s findings. Since no proof of rural classification or agricultural use existed on record & Assessee had not cooperated at any stage, Tribunal upheld CIT(A)/NFAC’s order sustaining LTCG addition of Rs.2,92,57,000. Appeal dismissed.
FULL TEXT OF THE ORDER OF ITAT PUNE
This appeal filed by the assessee is directed against the order dated 25.07.2025 of the Ld. CIT(A) / NFAC, Delhi relating to assessment year 2013-14.
