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2023 (1) TMI 621 - ITAT MUMBAIDeduction u/s 54F - AO denied the claim of deduction of payment made for purchase of property beyond the period of 3 years from the date of the sale of the original property - HELD THAT:- As submitted that the delay in investment beyond the period of 3 years was beyond control of the assessee and mainly due to the delay on account of the builder not being able to complete the construction as per the time frame agreed initially. During the course of hearing, assessee was asked to submit necessary documents in support of the contention that delay in investment by the assessee was due to the delay on the part of the builder in not completing the construction as per the time frame. However, no such evidences were furnished before us. In such circumstances, the ratio of the decisions relied upon by assessee cannot be applied over the facts of the instant case. As noted by the Ld.CIT(A) that the provisions claiming exemption has to be interpreted strictly. In view of the above facts and circumstances and the binding precedent followed by the Ld.CIT(A) on the issue in dispute, we do not find any error in the order of the Ld.CIT(A) on the issue and accordingly, we uphold the same. Ground 2 of the appeal of the assessee is accordingly dismissed.
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