Hari Chand v. ITO (2023) 155 taxmann.com 492/ 105 ITR 610 (Amritsar)(Trib)

S. 69A : Unexplained money-Difference between sale consideration shown in registered deed and that deposited in bank account-Appeal arising out of lack of verification-Matter remitted to Assessing Officer for adjudication de novo.

The assessee deposited cash in the bank account amounting to Rs. 90,17,000 and claimed that the amount was received from sale of property. The Assessing Officer assessed the amount as unexplained cash deposit on the ground that that the registered deed showed the sale consideration of Rs. 24,65,000 and confirmed the addition u/s. 69A of the Income-tax Act, 1961. During the assessment, further addition was made on undisclosed interest income amounting to Rs. 60,996 with the total income of the assessee.

The appeal arose out of lack of verification by the Department. With consent of both the parties, the matter was remitted to the Assessing Officer for further adjudication de novo after providing reasonable opportunity of being heard to the assessee in the set aside proceeding. (AY 2011-12)