2022 (3) TMI 74

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....Sr. DR ORDER Per Yogesh Kumar U. S. , JM This appeal is filed by the assessee against the order dated 28/12/2018 passed by the CIT(A)-33, New Delhi for Assessment Year 2014-15. 2. The facts in brief are that, the assessee is a private limited company and is assessed to tax year after year. The assessee is in the business of manufacture of sign boards and trading in reflective sheets, v....

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....ed 28.12.2018, the Ld. CIT(A) has allowed the appeal regarding late payment of Employee Share PF and also allowed the payment of rent up to 12.05.2013 but the payment of rent between 13.05.2013 to 30-09-2013 has not been allowed by making following observation: 'In terms of sub-section (47) of section 2 of the IT Act, the sale occurred on 13.5.2013 and the assessee had become the owne....

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....tly the disallowance of the rent of Rs. 18,00,000/- paid to the owners of the property till the date of actual realization of cheques by the Assessing Officer and Rs. 13,83,871/- out of Rs. 18,00,000/- sustained by the CIT (Appeals), is arbitrary, unjust and at any rate very excessive. 2) That the CIT (Appeals) has erred on facts and under the law in holding that in terms of Section 2(47)....

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....f the subject property vide rent agreement dated 25.03.2013 on rent of Rs. 3 lacs rupees per month. During the year under consideration, i.e. 2014-15 with an intention to purchase the very same property, entered into an agreement to sell on 13-05-2013 with its owners i.e. Mr. Ravinder Nath Hasija and Mr. Dharmveer Hasija, for total sale consideration of Rs. 5,50,00,000/-. As a part of Sale conside....