Validity of reopening an assessment beyond four years from the end of the relevant assessment year, denial of deduction u/s 54F, and the addition on the ground of owning more than one residential house. The key points are: the assessee did not fail to furnish requisite details, satisfying the proviso to Section 147; the Assessing Officer could not have validly assumed jurisdiction u/s 147 based on website information; different floors of a property cannot be construed as independent residential units, as decided by the Tribunal in the assessee's own wealth tax case; merely having several independent residential units does not impact the claim for deduction u/s 54F. The reassessment proceedings were quashed, and the assessee was entitled to a deduction of Rs. 90 crores u/s 54F. The denial of deduction u/s 54F for not utilizing the entire sale proceeds was addressed, clarifying that no deduction u/s 80G was claimed for the donation to the trust. The loan from Alert Buildtech was accepted as genuine, and no addition was made u/s 68.
Validity of reopening an assessment beyond four years from the end of the relevant assessment year, denial of deduction u/s 54F, and the addition on the ground of owning more than one residential house. The key points are: the assessee did not fail to furnish requisite details, satisfying the proviso to Section 147; the Assessing Officer could not have validly assumed jurisdiction u/s 147 based on website information; different floors of a property cannot be construed as independent residential units, as decided by the Tribunal in the assessee's own wealth tax case; merely having several independent residential units does not impact the claim for deduction u/s 54F. The reassessment proceedings were quashed, and the assessee was entitled to a deduction of Rs. 90 crores u/s 54F. The denial of deduction u/s 54F for not utilizing the entire sale proceeds was addressed, clarifying that no deduction u/s 80G was claimed for the donation to the trust. The loan from Alert Buildtech was accepted as genuine, and no addition was made u/s 68.
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