https://www.taxtmi.com/caselaws?id=759429 The ITAT Delhi quashed reassessment proceedings initiated beyond four years, ruling that the AO lacked valid jurisdiction under section 147 as the assessee had furnished all requisite details and no failure occurred. The tribunal held that information from government websites cannot constitute fresh tangible material warranting reopening. On merits, the tribunal allowed section 54F deduction of Rs. 90 crores, determining that basement and second floor of the same property constitute a single residential unit, not separate properties, based on prior wealth tax proceedings. The AO's denial of deduction was rejected as the assessee had timely deposited sale proceeds in capital gains account scheme and obtained genuine loan from Alert Buildtech for investment purposes. en-us Wed, 25 Sep 2024 00:00:00 +0530 Mon, 30 Sep 2024 10:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=759429 The ITAT Delhi quashed reassessment proceedings initiated beyond four years, ruling that the AO lacked valid jurisdiction under section 147 as the assessee had furnished all requisite details and no failure occurred. The tribunal held that information from government websites cannot constitute fresh tangible material warranting reopening. On merits, the tribunal allowed section 54F deduction of Rs. 90 crores, determining that basement and second floor of the same property constitute a single residential unit, not separate properties, based on prior wealth tax proceedings. The AO's denial of deduction was rejected as the assessee had timely deposited sale proceeds in capital gains account scheme and obtained genuine loan from Alert Buildtech for investment purposes. Case-Laws Income Tax Wed, 25 Sep 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=759429