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2023 (4) TMI 192 - ITAT INDORERevision u/s 263 - as per CIT the exemption u/s 54F has been wrongly allowed to assessee and by not declaring notional income from properties under “Income from house property” head, there was underassessment of taxable income - HELD THAT:- To address this query of Bench, Ld. AR sought adjournments from time to time to bring on record the bank statement from which investment would have been made in the impugned property. But, however, ultimately the Ld. AR admitted inability of assessee to submit the same. Therefore, we have no option except to conclude that since the “flat at Pune” is appearing in the Balance-Sheet of assessee, the investment had also been made by assessee. That means, the assessee was owner of at least 2 residential houses, viz. one at S.No. (iii) admitted by assessee; and another at S.No. (ii) being the “flat at Pune”. Having found that the assessee was owner of at least 2 residential houses, we are in agreement with the twin-issues raised by Ld. PCIT i.e. (i) the exemption u/s 54F has been wrongly allowed to assessee; (ii) by not declaring notional income from properties under “Income from house property” head, there was underassessment of taxable income. Therefore, the Ld. PCIT has rightly termed the assessment-order as erroneous in so far it is prejudicial to the interest of revenue.Decided against assessee.
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