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2019 (11) TMI 1712 - AT - Income TaxRevision u/s 263 by CIT - allowance claimed by assessee on rubber tree plantation under Rule 7A(2) - HELD THAT:- Admittedly, Ld.AO at the time of original assessment proceedings did not verify claim of assessee under Rule-7A(2). There is nothing on record to establish that even a query was raised by AO in regards to the claim. From the statement furnished by the assessee, we note that the amount represent opening balance and the same has been capitalized by the assessee. During the year under consideration assessee has incurred expenses of ₹ 8,80,48,770/- out of which a sum of ₹ 89,10,452/- was capitalized. Accordingly, a sum of ₹ 7,91,38,318/- was claimed as expenses under Rule 7A. We notice that Ld. CIT has not appreciated these facts, in proper perspective. We are of the opinion, that CIT(A) should look into the facts once again. Accordingly, we set aside the order passed by Ld. CIT, and restore all issues to his file for examining them afresh - Appeal filed by assessee allowed for statistical purposes.
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