Appeal partly granted for deductions on flats, further examination required for improvement expenses.

The tribunal partly allowed the appeal, granting deductions under section 54F for flats purchased in the names of the appellant's wife and son. The tribunal directed further examination of the claimed expenditure for improvement on the new flats. The issue of interest under section 234A/234B was not extensively discussed, and the general fourth issue was left for future arguments.

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Issues:
1. Deduction under section 54F denied for flats purchased in the name of appellant's wife and son.
2. Deduction claimed for improvement on purchase of new flats disallowed.
3. Charging of interest under section 234A/234B on returned income.
4. Other grounds to be argued later.

Detailed Analysis:
1. The appeal involved the denial of deduction under section 54F for flats purchased in the name of the appellant's wife and son. The assessee purchased three flats, constituting one unit, in the names of his wife, son, and himself. The assessing officer allowed deduction only for the flat purchased in the appellant's name. The tribunal referred to similar cases and held that if the sale consideration is applied by a person for purchasing a residential house in the name of their wife or son, they are eligible for deduction under section 54F. The tribunal reversed the decision of the CIT(A) and allowed the deduction for the flats purchased in the names of the wife and son.

2. The second issue pertained to the deduction claimed for improvement on the purchase of new flats. The assessee failed to provide evidence for the claimed expenditure before the assessing officer and the CIT(A). Although bills for furnishing and renovation were submitted during the tribunal hearing, doubts remained regarding the genuineness of the expenditure. The tribunal directed the issue to be restored to the file of the CIT(A) for further examination and verification of the claimed expenditure, ensuring the assessee is given a fair opportunity to present their case.

3. The third issue addressed the charging of interest under section 234A/234B on the returned income instead of the assessed income. The tribunal did not provide a detailed analysis of this issue in the judgment.

4. The fourth issue was of a general nature and required no adjudication, as it was left for further arguments at the time of hearing.

In conclusion, the tribunal partly allowed the appeal for statistical purposes, granting deductions under section 54F for the flats purchased in the names of the appellant's wife and son, while directing further examination of the claimed expenditure for improvement on the new flats.

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