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ITAT allowed the assessee's appeal, holding that the AO exceeded jurisdiction by converting a limited scrutiny into a de facto complete assessment and making additions without proper mandate; those additions were therefore unsustainable. On exemption under section 54F, the Tribunal found the assessee had deposited and utilized the entire capital gains sum pursuant to the prescribed scheme within the statutory three-year period for construction, and administrative delays in final approvals and physical completion did not defeat the beneficial object of section 54F. Consequently the section 54F exemption was recognised and the impugned addition reversed.
ITAT allowed the assessee's appeal, holding that the AO exceeded jurisdiction by converting a limited scrutiny into a de facto complete assessment and making additions without proper mandate; those additions were therefore unsustainable. On exemption under section 54F, the Tribunal found the assessee had deposited and utilized the entire capital gains sum pursuant to the prescribed scheme within the statutory three-year period for construction, and administrative delays in final approvals and physical completion did not defeat the beneficial object of section 54F. Consequently the section 54F exemption was recognised and the impugned addition reversed.
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