2021 (6) TMI 129

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.....: This appeal by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals)-33, Mumbai ('ld.CIT(A) for short) dated 15.03.2019 and pertains to the assessment year (A.Y.) 2010-11. 2. The grounds of appeal read as under: 1. On the facts and circumstances of the Case and under the provisions of Law, The Learned Commissioner of Income Tax (Appeal-33)....

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....x (Appeal-33) Mumbai has erred in appreciating the fact that additional claim made during the appeal proceedings need to be decided on merit and if details were incomplete the same should be asked during the appeal proceedings. 4. Your appellant humbly submits the appellant is entitled to deduction u/s 54F arising out of investments made in purchasing a residential house. 5. Your....

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....course not in pursuance of notice u/s 148. Hence, such claim u/s 54 was not made in return. Further, the deduction was not claimed at any time of point during the scrutiny proceedings. Therefore, the same was never examined by the AO. During the appellate proceedings, agreement for purchase of new flat was filed an claim u/s 54 was made on that basis. I am of the view that such claim cannot be ent....