Strict compliance and evidence verification govern section 54F relief and unexplained investment additions, leading to remand.

Deduction under section 54F requires purchase or construction of the new residential house within the statutory period, and an unregistered banakhat alone was not treated as conclusive proof of compliance where the payment flow and related evidence needed closer scrutiny. The addition under section 69 for unexplained investment also turned on incomplete verification of bank statements, payment details, and books of account. Both issues were remanded to the Assessing Officer for fresh examination after giving the assessee an opportunity to support the claim, and the appellate relief was not finally sustained.

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Issues: (i) Whether deduction under section 54F of the Income-tax Act, 1961 was admissible on the basis of the claimed investment and banakhat within the prescribed period. (ii) Whether the addition made under section 69 of the Income-tax Act, 1961 for unexplained investment was liable to be deleted or required further verification.

Issue (i): Whether deduction under section 54F of the Income-tax Act, 1961 was admissible on the basis of the claimed investment and banakhat within the prescribed period.

Analysis: Section 54F grants relief only where the assessee purchases or constructs the new residential house within the statutory time frame. The record showed that the substantial payment for the flat was made before the transfer date and the registered sale deed was executed after the prescribed period. The Tribunal held that an unregistered banakhat, by itself, could not be treated as conclusive compliance with the statutory conditions without proper examination of the flow of funds and the surrounding evidence.

Conclusion: The issue was restored to the Assessing Officer for fresh examination, and the relief granted by the first appellate authority was not sustained.

Issue (ii): Whether the addition made under section 69 of the Income-tax Act, 1961 for unexplained investment was liable to be deleted or required further verification.

Analysis: The assessee claimed that the investment was made through banking channels and that supporting statements and payment details were furnished, but the assessment order did not show detailed verification of those materials. The Tribunal found the evidentiary position incomplete and considered it appropriate to have the sources of funds, bank statements, and books of account examined afresh by the Assessing Officer after affording adequate opportunity to the assessee.

Conclusion: The issue was remanded to the Assessing Officer for fresh adjudication.

Final Conclusion: The Revenue's appeal did not result in a final substantive allowance on the merits and was disposed of by remand of both disputed issues for reconsideration.

Ratio Decidendi: Relief under sections 54F and 69 depends on strict statutory compliance and proper evidentiary verification, and where the factual foundation is incomplete, the matter may be restored for fresh examination rather than finally decided.

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