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TMI Blog2023 (12) TMI 1036X X X X Extracts X X X X X X X X Extracts X X X X ..... Vizay B. Vasanta, CIT-DR ORDER PER DR. B. R. R. KUMAR:- The present appeal has been filed by the assessee against the order of Assessing Officer dated 27.01.2023 for the AY 2015-16. 2. The assessee has raised the following grounds of appeal are as under:- 1. That the order is bad in law and against the fact of the case. 2. That the Ld. Assessing Officer has ignored the observations made in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer has erred by not raising the point related to the Rs. 1,29,00,000/- before/during the assessment proceedings. 6. On the facts and circumstances of the case and in law the Ld. Assessing Officer has erred by initiating the penalty proceeding under section 271(1)(c) of the Income Tax Act, 1961. 3. During the course of assessment proceedings the assessee, vide statutory notice u/s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 85/-. The AO held that the Assessee must purchased new asset within 02 years of transfer i.e. before 17.04.2016. The possession of new asset was taken 04.07.2016 and conveyance deed was executed on 29.04.2016. Hence the AO held that new asset cannot be considered as acquired within 02 years of transfer of original asset. 4. Heard the arguments of both the parties and perused the material availabl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ated as cases of construction for the purposes of sections 54 and 54F of the Income-tax Act. The Board has since received representations that even in respect of allotment of flats/houses by co-operative societies and other institutions, whose schemes of allotment and construction are similar to those of Delhi Development Authority, a similar view should be taken. 2. The Board has considered the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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