2015 (2) TMI 69

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....d sold two plots of land for Rs. 8,98,775/-. The original assessment made under Section 143(3) was set aside by the CIT(A) vide order dated 28.08.1989 and the Assessing Officer was directed to make fresh assessment. Thereafter, the Assessing Officer completed the fresh assessment and passed his order on 31.03.1992. In the fresh assessment, the assessee claimed deduction under Section 54E of the Act on the basis of investment of Rs. 1,89,400/- made in NRDB on 20th February, 1987, within six months of the receipt of final installment. However, the Assessing Officer, rejected the claim of the assessee. 2.1. Against the order of the Assessing Office, the assessee filed an appeal before the Commissioner of Income Tax (Appeals). The CIT(A) vid....

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....o be counted from 21st September, 1985 i.e. from the date of receipt of consideration. 5. Learned advocate for the respondent revenue has supported the impugned judgment and order of the Tribunal and submitted that the present appeal deserve to be dismissed in view of the concurrent findings of all the authorities namely the Assessing Officer, CITA(A) and the Tribunal. He has also drawn our attention to the reasonings adopted by the Tribunal while deciding the appeal. Therefore, he urged that this Court may dismiss the present appeal. 6. We have heard learned advocate for the parties and perused the material on record. In our view, the contention of learned advocate for the appellant-assessee is misconceived inasmuch as the six months....