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The short issue for consideration was the value of the land sold at the relevant point of time. The AO in the facts of the present case should have carried out necessary enquiries as he had the PAN details of the purchaser. Accordingly, we find that in the peculiar facts and circumstances of the present case, the Tax Authorities have failed to exercise their powers which they are vested with and in the face of the inability of the assessee to produce the concerned purchasers, the Department who has the PAN numbers and has traced the parties in Amritsar should have no hesitation in calling forth and examining the issues as the purchasers may be front-men of some builders etc. having deep pockets. The relevant facts in the form of the value of the specific property at the relevant point of time mayalso be a relevant aspect to be taken into consideration. Accordingly, in the interest of justice, the issue is restored back to the file of the AO with a direction to pass a speaking order in accordance with law after giving the assessee a reasonable opportunity of being heard.

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Section 69A of the Income-tax Act, 1961 — Unexplained money— Additions stood confirmed since the tax authorities have doubted the availability of the funds in the hands of the father which gifts have been treated to be not genuine in the hands of the two sons — Raghubir Singh vs. ITO [2020] 180 Itd 719 (Chd)

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