2023 (5) TMI 410

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....orey, 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 days. The assessee has filed an affidavit expla....

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....d 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 draft order because of the failure of the asses....

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....s, 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 towards the above four things. At this stage, it is....

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....pment 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. Thirdly, even if we go with the hypothesis that....