TMI Blog2020 (8) TMI 67X X X X Extracts X X X X X X X X Extracts X X X X ..... Therefore, it is quite possible that the assessee might not have been able to provide the requisite documents before the Ld. Revenue Authorities at the time of hearing. Hence, in the interest of justice, we hereby remit the matter back to the file of Ld. AO with directions to admit the additional evidence filed before us and also any other relevant documents filed by the assessee for the first time and thereafter decide the issue afresh in accordance with merit and law after providing proper opportunity to the assessee of being heard. Appeal of the assessee is allowed for statistical purposes Order being pronounced after ninety (90) days of hearing - COVID-19 pandemic and lockdown - HELD THAT:- Taking note of the extraordinary situatio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s. 3. The assessee has raised several grounds in her appeal and they are reproduced herein below for reference: - 1. The order of the Appellate Commissioner is contrary to law, facts and circumstances of the case. 2. The Appellate Commissioner ought not to have rejected the ground of jurisdiction by the A. O., for issue of notice u/s 147 of the Income-Tax Act, 1961. 3. The Appellate Commissioner ought ~. to have observed that the rejection of A.O. was u/s 54F, while the assessee claimed u/s 54 in the additional ground filed. 4. The Appellate Commissioner ought not to have rejected the claim of the assessee made ix] s 54, by observing that no investment in the property was made for claim of deduction u/s 54. 5. An ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... for denying the benefit of deduction U/s. 54F of the Act because the assessee has not furnished any cogent evidence. 6. At the outset, the Ld.AR furnished a paper book before us running from 1 to 86 pages wherein item No. 9 to 14 are stated to be additional evidence such as construction permission issued by the Panchayat Office dated 22/12/2009, copy of approval plan for 1st and 2nd Floor from Gram Panchayat, Housing Loan sanction, valuation report, tax receipt issued by the Gram Panchayat, copy of the challan for the payment made to Electricity Department for obtaining electricity and certain other relevant documents. The Ld. AR argued by stating that the additional evidence submitted by the assessee will establish that the assessee is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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