2023 (5) TMI 410

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....i For the Revenue : Shri Shivraj Morey, CIT-DR ORDER PER R.S. SYAL, VP : This appeal by the assessee is directed against the final assessment order dated 27-04-2022 passed by the Assessing Officer (AO) u/s.143(3) read with section 144C(13) of the Income-tax Act, 1961 (hereinafter also called 'the Act') in relation to the assessment year 2019-20. 2. The appeal is time barred by 37 da....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ds development work carried out. On being called upon to substantiate and furnish necessary copies of bank account and invoices through which said development work was carried out, the assessee submitted confirmation from Pallod & Associates, the developer, affirming that the development cost of Rs.2,40,000/- and Rs.3,00,000/- was incurred on 22-09-1998. The AO did not grant such deduction in the ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....iven by the developer, who thereafter raised bills, copies of which have been placed at pages 18 and 19 of the paper book. It can be seen that the estimate given by the developer, namely, Pallod & Associates on 20-07-98 was towards Barbed wire fencing; Ornamental entrance door; Construction of shed; and Water reservoir. Thereafter, there is a so called Bill dated 22-09-98 given by the developer to....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....not adduce any evidence of having done any development work on the property by furnishing the direct invoices for the development work. Secondly, even if it is presumed that the development work was actually carried out as claimed through the estimate/Bill of the developer, it is hard to accept that the development of the property was got done by the assessee before the date of its purchase itself....