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Rule 27 permits a respondent to support the appellate order on an additional ground, and the alleged allotment breach could not justify disallowance in Assessment Year 2011-12 because the Revenue's material related to a later year. On the merits, the Revenue failed to prove breach of the beneficial housing-project deduction condition under section 80IB(10)(f): it relied mainly on a third-party statement, produced no reliable documentary evidence that the flats were really allotted to one person through nominees, and was denied effective cross-examination. The Tribunal treated the statutory condition as requiring cogent proof and sustained deletion of the disallowance; the Revenue's appeal for Assessment Year 2012-13 was rejected on the same reasoning.
Rule 27 permits a respondent to support the appellate order on an additional ground, and the alleged allotment breach could not justify disallowance in Assessment Year 2011-12 because the Revenue's material related to a later year. On the merits, the Revenue failed to prove breach of the beneficial housing-project deduction condition under section 80IB(10)(f): it relied mainly on a third-party statement, produced no reliable documentary evidence that the flats were really allotted to one person through nominees, and was denied effective cross-examination. The Tribunal treated the statutory condition as requiring cogent proof and sustained deletion of the disallowance; the Revenue's appeal for Assessment Year 2012-13 was rejected on the same reasoning.
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