2023 (7) TMI 990

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....the assessee has filed this appeal on the grounds raised in Appeal-Memo. 2. Heard the learned Representatives of both sides at length and case records perused. 3. The Registry has informed that the present appeal is delayed by 232 days (the assessee has calculated 289 days). Ld. AR submitted that the assessee has filed an application supported by an affidavit duly notarized praying for condonation of delay. The reason of delay averred in the affidavit is such that whenever the assessee enquired from his counsel about compliance of matter, the counsel informed that all compliances have been done. This way, despite repeated reminders the Counsel did not give proper feedback. Ultimately, the assessee approached another counsel, who verified ....

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.... Rs. 2,12,87,525/- (+) Deposit of Rs. 40,00,000/- in Capital Gain Deposit Scheme, 1988, with an objective to construct a residential house property within a period of 3 years. The AO accepted the exemption claimed by assessee and allowed same while passing assessment-order. 5. Subsequently, Ld. PCIT examined the records of assessment proceedings and found that during assessment-proceeding, the assessee had not furnished any documentary-proof in support of completion of construction of residential house within a period of 3 years. Therefore, the AO has not verified the claim assessee for exemption u/s 54F. Accordingly, the PCIT termed the assessment-order as erroneous-cum-prejudicial to the interest of revenue and initiated action of revisi....