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In the instant case which relates to purchaser of plot of land and the addition is made for unexplained investment. There is no iota of evidence placed on record which could show that any investigation has been carried out by the Revenue authorities in relation to the seller of the property for the actual consideration received by him. The addition in the hands of assessee which is merely based on the Jantry rates, so far as s. 50C of the Act is concerned the same is not applicable on the assessee as the assessee is purchaser whereas s. 50C of the Act applies to seller.

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Sec. 50C, 69 & 153A of Income-tax Act, 1961 — Search & seizure —  Assessee filed the appeals against the order of COIT(A) which are arising out of the order under s. 153A r/w s. 143(3) of the IT Act 1961 on the ground that CIT(A) erred in maintaining the addition to the extent of Rs. 19,41,000 (out of Rs. 1,30,00,000) made under s. 69B towards unexplained investment in purchase of plot without properly appreciating the facts of the case and submissions made before her. ITAT allowed the appeal of the assessee holding that:- Unless any documents or evidence is found which could prove that unexplained investment has been made by the assessee over and above the purchase consideration mentioned in the registered deed, there is no justification in the action of the Revenue authorities applying the valuation of the property made by the Stamp Valuation Authority. Therefore, set aside the finding of CIT(A) and delete the addition of Rs. 19,41,000 sustained by the CIT(A) — B.S. ASSOCIATES Vs. DY. CIT [2020] 203 TTJ 728 (ITAT-INDORE)

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