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    <title>Rule 27 support and year-specific evidence defeated housing deduction disallowance for alleged allotment breach claims</title>
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    <description>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&#039;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&#039;s appeal for Assessment Year 2012-13 was rejected on the same reasoning.</description>
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    <pubDate>Fri, 19 Jun 2026 08:24:43 +0530</pubDate>
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      <title>Rule 27 support and year-specific evidence defeated housing deduction disallowance for alleged allotment breach claims</title>
      <link>https://www.taxtmi.com/highlights?id=100918</link>
      <description>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&#039;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&#039;s appeal for Assessment Year 2012-13 was rejected on the same reasoning.</description>
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      <pubDate>Fri, 19 Jun 2026 08:24:43 +0530</pubDate>
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