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Section 54F time limit and section 69 verification issues led to remand for fresh factual examination.

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Full Text of the Document

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....Section 54F requires purchase of the new residential house within the statutory period, and an unregistered banakhat by itself was not enough to prove completion of purchase within that time frame. Because the substantial payment was made more than one year before transfer and the registered sale deed was executed beyond two years after transfer, the deduction could not be sustained on the existing record; the issue was restored for limited verification of the flow of funds and linkage with sale proceeds. The addition under section 69 also required fresh factual examination, as the bank statements and documentary evidence were not properly verified and it was unclear whether all material had been before the AO. Both matters were remanded.....