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2023 (10) TMI 1239 - AT - Income TaxRevision u/s 263 - As per CIT Allowability of corresponding expenses for the purpose of computing the long term capital gains not taken by AO - HELD THAT:- There is not even a single notice by the AO raising specific queries of the details of cost of acquisition/ improvement claimed at the assessee’s behest whilst computing his capital gains. We make it clear that the assessee’s case before us is that although we are in assessment year 2015-16; however, the impugned expenditure had been incurred from assessment year 1989-90 onwards. That being the case, it was assessee’s bounden duty only to file the requisite supportive material during the course of assessment on being put to question by the AO. As admittedly not been done as the facts before us speak for themselves. Faced with the situation, we quote Malabar Industrial Company Ltd [2000 (2) TMI 10 - SUPREME COURT] Rampyari Devi Saraogi [1967 (5) TMI 10 - SUPREME COURT], Tara Devi Aggarwal [1972 (11) TMI 2 - SUPREME COURT] and Paville Projects Pvt. Ltd [2023 (4) TMI 295 - SUPREME COURT] to confirm the learned PCIT’s revision directions. Decided against assessee.
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