Held, that as the assessee was pursuing remedy by way of application under section 154 of the Income-tax Act, 1961, which was dismissed by the National Faceless Appeal Centre, delay of 89 days in filing the appeal is  condoned. Held that the sole basis for the initiation of the proceedings under section 148 was the information received from the National e-Assessment Centre, according to which, the sale deed had been executed  for a sale consideration in respect of a property measuring 11 cents situated in Kavoor village, Mangalore Taluk, wherein the assessee was neither the purchaser nor the vendor. On the other hand, the assessee produced her sale deed showing sale of a property by M measuring 0-05.75 acres situated in Kotekar village, Mangalore Taluk for a sale consideration lower than that shown in the former document. The assessee had produced the source for the transaction as loan availed of from a bank. The Assessing Officer had made addition on the basis of wrong assumption of facts. The addition made by the Assessing Officer under section 69A is deleted. Tribunal also held that without the addition, the assessee’s income did not exceed the maximum amount and, hence, is  not liable to tax. Therefore, no advance tax was payable and the invocation of section 249(4) by the Commissioner (Appeals) is not justified. (AY. 2018-19)