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TMI Blog2021 (7) TMI 13X X X X Extracts X X X X X X X X Extracts X X X X ..... cultural activities. In the condonation applications common reason is death of one of the family members and lack of necessary advice to file the appeals and time limit. We have given thoughtful consideration and in the larger interest of justice and the reasons mentioned by the respective assessees, condone the delay in filing of instant appeals and admit them for adjudication. 3. Assessee(s) has raised following common grounds of appeal in ITANos.870 to 874/Ind/2019:- GROUND I: 1.On the facts and circumstances of the case and in law, the Learned Principal Commissioner of Income tax -I, Indore ["the PCIT"] erred in invoking provisions of section 263 of the Income Tax Act, 1961 ("the Act") and directing revision of the assessment order passed u/s. 143 (3)/147 of the Act by the Income Tax Officer-1(4), Indore ("the AO") for examination of capital gains and deductions on the alleged ground that the assessment order was erroneous and prejudicial to the interest of the revenue. 2.The Appellant prays that since the assessment order passed by the AO was after making specific and full enquiries therefore the assessment order cannot be regarded as erroneous and accordingly the actio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ts and in the circumstances of the case and in law the Ld. CIT erred in set aside the order as passed by the assessing officer u/s 143(3) r.w.s. 147 of the Act by invoking the provision of section 263 of the Act even when the order as passed by the assessing officer was neither erroneous prejudicial to the interest of the revenue. 1.2 That on the facts and in the circumstances of the case and in law the Ld. CIT erred in set aside the order as passed by the assessing officer by invoking the provision of section 263 of the Act even when the order was passed by the assessing officer u/s 143(3) r.w.s. 147 of the Act after full application of mind. 2. That on the facts and in the circumstances of the case and in law the Ld. CIT erred in set aside the order as passed by the assessing officer by invoking the provision of section 263 of the Act merely for applying the sale consideration as per provision of section 50C of the Income Tax Act even when consideration was received by the assessee in previous years as per guidelines as applicable in that year. 3. That the appellant reserves its right to add, alter and modify the grounds of appeal as taken. Assessee(s) has raised following ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... source of income is from agricultural operation, capital gain and income from other sources. The assessee along with family members entered into an understanding for sale of his agricultural land admeasuring 3.522 hectares with Shri Vijay Mirchandani Ji who acted on behalf of M/s Global Developers for sale consideration of Rs. 1,91,48,000/- out of which Mr. Kamal Kishore Mukati had to received 1/5th share i.e. Rs. 38,29,600/-. This sale agreement was executed on 31.03.2016 and the consideration was received through banking channels in the respective bank accounts of the sellers on different dates soon after entering the agreement. The sale deed was finally registered on 02.04.2008 between the assessee and M/s. Global Developers. Through annual information return Ld. AO received information about the transaction of sale of immovable property registered on 02.04.2008. In order to initiate the assessment proceedings u/s 147 of the Act, notice u/s 148 of the Act was duly served upon the assessee and in compliance thereto return of income for A.Y.2009-10 was filed on 18.04.2016, showing income at Rs. 1,72,999/- and agricultural income of Rs. 1,37,500/-. Detailed computation of income al ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... provisions of section 263 of the Act in case of all the assessee(s) in the instant appeals and issued show cause notice u/s 263 of the Act. Since content of most of the notices issued are common depending on the value of sale consideration and the share of sale consideration and deduction claimed u/s 54of the Act by the respective assessees, we are reproducing below the show cause notice issued in the case of Kamal Kishore Mukati ITANo.870/Ind/2019, Shankarlal Mukati ITANo.433/Ind/2018, Radheshyam Mukati ITATNo.435/Ind/2018 & Subhash Mukati L/H Shri Badrilal Mukati ITANo.425/Ind/2018: Kamal Kishore Mukati 2.1 The relevant portion of the show cause notice u/s 263 is reproduced as under:- (i) It is observed that your case was reopen on the basis of AIR information relating to the A. Y. 2009-10 on account sale of immovable property. As per records you had sold joint agricultural land for a stated consideration of Rs. 1,91,48,000/- vide sale deed dated 02/04/2008 and shown share in the sale consideration was Rs. 38,29,600/- (1,91,48,000/5) Whereas the market value of the land was assessed by the Sub registrar at Rs. 3,60, 00,000/-. Further, the AD had also taken sales considerati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at Rs. 1,85,02,000/-. Further, the AO had also taken sales consideration at Rs. 28,60,000/-[ i.e.1/3 of 85,80,OOO] and accordingly calculated Long Term Capital Gain while completing the reassessment u/s 147/143(3) of the Income Tax Act. 1961.However, in view of section 50C, the sale value of the land was required to be taken at Rs. 61,67,333/- (1,85,02,000/3) instead of Rs. 28,60,000/-. Subhash Mukati It is observed that your case was reopen -on the basis of AIR information relating to the A. Y. 2009-10 on account sale of immovable property. As per records you had sold joint agricultural land for a stated consideration of Rs. 99,26,000/- vide sale deed dated 11/04/2008 and shown share in the sale consideration was Rs. 28,60,000/- (85,80,00013). Whereas the market value of the land was assessed by the Sub registrar at Rs. 2,07,61,000/-. Further, the AO had also taken sales consideration at Rs. 99,26,000 and accordingly calculated Long Term Capital Gain while completing the reassessment u/s 147/143(3) of the Income Tax Act. 1961.However, in view of section 50C, the sale value of the land was required to be taken at Rs. 2,07,61,000/- (instead of Rs. 99,26,000/-. 9. Since we are d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .2008. Thus even though the assessee may have entered into an agreement on 31.03.2006 for sale of the property in question and may have received part consideration, possession was not handed over till execution of the deed of 11.04.2008. therefore, the claim of the assessee that the land had been sold as per agreement dated 31.03.2006 is not correct. 4.1.4 Moreover, it is also observed agreement dated 31.03.2006 was entered into by the assessee and other Co-owners with Mis Global Developers, 210, Shalimar Corporate Centre, 8- B, South Tukoganj, Indore, whereas the land was ultimately sold by them on 11.04.2008 to Mis Coral Infrastructures Private Limited, 505-506, Shalimar Maurya Park, New Link Road, Andheri (E), Mumbai. Therefore, the plea of the assessee that the property had already been transferred (to Mis Global Developers, Indore) in pursuance of agreement dated 31.03.2006 is not correct as the same land cannot again be transferred to a, different entity (Mis Coral Infrastructures Private Limited) vide sale deed dated 11.04.2008. In this regard assessee has contended that sale was made to Shri Vijay Mirchandani who was person concerned in both Mis Global Developers and Mi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... truction of the house as per the sale deed dated 11.04.2008 as per the prescribed conditions uls 54F of the IT Act. Apparently, the AO has not allowed the deduction after examining the issue correctly. Accordingly, the order of the AO is erroneous and prejudicial to the interest of the revenue. 4.4 An order can be erroneous & prejudicial to interest of revenue on the ground that in the circumstances of the casethe Assessing Officer should have made further inquiries. It is duty of the Assessing Officer to ascertain the truth of the facts stated by the assessee. It is incumbent on the Assessing Officer to investigate the facts stated when circumstances would make such an inquiry prudent. 5. As per provisions of section 263, the Pro commissioner of Income tax may call for and examine the record of any proceedings and if he considers that any order passed therein by the assessing officer is erroneous in so far as it is prejudicial to the interest of the revenue, he may after giving the assessee an opportunity of being hear and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case, justify, including an ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the case, the ITO should have made further enquiries before accepting the statements made by the assessee in his return. Following these two decisions of Hon'ble Supreme Court, Hon'ble Allahabad High Court has held in the case of Smt. Lajja Wati Singhal vs. CIT (1997) 138 CTR (All) 320 : (1997) 226 ITR 527 (All) that, an assessment made on income surrendered by the assessee without making any enquiry whether the same was in fact taxable in his hands was erroneous and prejudicial to the interest of the Revenue. Further, as held by Hon'ble Delhi High Court in the cases of Gee Vee Enterprises vs. Addl. CIT 1975 CTR (Del) 61 : (1975) 99ITR 375 (Del), Duggal & Co. vs. CIT (1994) 122 CTR (Del) 171 ; (1996) 220 ITR 456 (Del), it is incumbent on the AO to further investigate the facts stated in the retum when circumstances would make such an enquiry prudent and his order becomes erroneous if such an enquiry has not been made. Moreover, as held by Hon'ble Gujarat High Court in the case of Addl. CIT us. Mukur Corporation (1978) 111ITR 312(Guj), an order of assessment passed by the AO without making necessary enquiries on certain important points connected with tne assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ine the issues of capital gains and deductions thereon in the light of the observations made and after ascertaining all the facts and affording proper opportunity to the assessee take decision as per law. The order dated 19.04.2016 passed U/S 143(3)/147 is therefore set aside to above extent on the above issues with the direction to the AO for passing a fresh order taking into consideration the observations noted above as per law 10. Now the assessee is in appeal before the Tribunal. Ld. Counsel for the assessee vehemently argued referring to the following written submissions and various decisions referred therein contended that the Ld. Pr. CIT erred in assuming jurisdiction u/s 263 of the Act since there a detailed enquiry was conducted by the Ld. AO with regard to the transaction in question by way of calling of various documentary evidences which were duly filed and the same were going through before completing the assessment proceedings u/s 147 of the Act. Thus, this is neither a case of 'no' enquiry nor incomplete enquiry. Written synopsis filed by the Ld. counsel for the assessee is reproduced below: 1.1] The present appeal is filed against the order as passed under sectio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ever entered into an agreement for sale of his land with M/s Coral Infrastructure P Limited. Since, the assessee had received advance against the sale of land in term of sale agreement as executed on 31-03-2006 and therefore he has executed registry in the name of M/s Coral Infrastructure P Limited as directed by the buyer. It is pertinent to mentioned that Shri Vijay Mirchandani entered into an agreement with the assessee on behalf of his firm M/s Global Developers and finally registry was also executed with Shri Vijay Mirchandani as a director of M/s Coral Infrastructure P Limited. The amount as received by the assessee in the year 2005-06 and in 2006-07 was adjusted in the registry as executed. 1.5] That in view of the above facts, the Pr CIT was not justified in adopting the guideline as applicable in the year in which final registry was executed. 1.6] The Ld Pr CIT rejected the submission merely for the reason that sale agreement was executed by the assessee with another firm and registry was executed in the name of another firm. The Ld Pr CIT failed to appreciate that in the sale agreement itself in Para 5 on inner Page No 6 [ Page no 8 of the Compilation] it was stated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be considered the date on which the property was transferred. The Supreme Court held that when an agreement to sell in respect of immovable property is executed, a right in person am is created in favour of the vendee and when such a right is created in favour of the vendee, the vendor is restrained from selling the said property to someone else because the vendee gets a legitimate right to enforce a specific performance of the agreement. The Supreme Court, while considering the provisions of Section 2 (47) (ii) of the Act held that if a right in respect of any capital asset is extinguished and that right is transferred to someone else, it would amount to transfer of a capital asset. The Supreme Court held that once an agreement to sell is executed in favour of some person, the said person gets a right to get the property transferred in his favour and, consequently, some right of the vendor is extinguished. 13. Explanation 2 to Section 2(47) of the Act was added by Finance Act, 2012 with retrospective effect on 1.4.1962 and, consequently, the said provision would be applicable. The said explanation clearly provides that transfer of an asset includes disposing of or parting with a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ressed in the following decisions:- S.No Citation Reference 1 Ms ZubeidaShahanshah ITA No 519/ Lkw/2017 dt 31-01-2019 2 DharmshibhiSonaniVs ACIT, Surat [2016] 75 Taxmann.Com 141 [ Ahmedabad Bench ] 161 ITD 627 (Ahd ) 3 Hari Mohan Das Tandon (HUF) 169 ITD 639 (All) 4 M/s Jai Laxmi Developers (P) Ltd Vs DCIT ITA No 5578/ Del/ 2014 dt 5 SmtKundanbenAmbhai Shah V. ITO ITA No 3354/ Ahd/ 2014 dt 30-11-2017 1.9.3.1] Hon'bleLucknow Bench of ITAT in the case of Ms. Zubeida Shahanshah[ Appeal No ITA No 519/ LKW/ 2017 dt 31-01-2019 ] has held that: " 4.2 In view of the above facts and judicial precedents, we hold that the amendment to section 50C by the Finance Act 2016 has to be applied retrospectively as the amendment is curative in nature therefore, collector's rate prevalent at the time of entering agreement has to be taken as deemed consideration. Therefore, ground No. 2 is dismissed." 1.9.3.2] That Hon'ble Ahmedabad Bench of ITAT in the case of Dharamshi Bhai Sonani[ ITA No 1237/ Ahd/ 2013 dt 30-09-2016] has held that: [9] So far as the amendment to Section 50C being retrospective in effect is concerned, there is no doubt about the legal position. I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n pursuance to that sale agreement, registry was executed on 11-04-2018. The consideration as received by the appellant was utilized towards purchase of new Agricultural land. Hence, the Ld Assessing officer rightly allowed deduction under section 54B of the Income Tax Act. 2.7] That Hon'ble Jaipur Bench of ITAT in the case of SmtRukmani Devi AgrawalVs ITO [ Appeal No ITA No 557/ JP/ 2018 dt 18-09-2018 for the Asst Year 2013-14 ] had an occasion to discuss the similar issue and held that [ Refer Para 6.2 of the order ]: "6.2 The requirement for availing the benefit of Section 54B is to use the capital gain for purchase of new agricultural land and if the assessee does not receive the sale consideration then the question of purchasing new agricultural land does not arise and the very object of Section 54B of the Act would be defeated. Hence the receipt of compensation and payment of consideration for purchase of new asset are the relevant dates for determining the conditions of Section 54B of the Act are satisfied. In the case in hand, when the assessee has received the compensation prior to the payment of the purchase consideration for acquisition of new agricultural land then ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ious documentary evidences and submissions of the Appellant such as Affidavit in support of construction of new house, withdrawal of amount from bank for construction activity, Physical existence of new residential house which was also confirmed by the Valuation report by chartered engineer. Further as desired by the learned AO the valuation of the residential house was also obtained and submitted to the learned AO which was found to be much higher than the deduction claimed. Also the construction of new house has not been doubted by any of the authority. Based on such evidences and enquiries made the AO was satisfied about the construction of the new residential house and the fact that the claim was commensurate to the construction cost incurred and amount withdrawn from bank account for payment of construction cost during such period. Accordingly the learned AO allowed the claim of deduction. 3.2] The PCIT raised the issue that the valuation report is dated 22-03- 2016 and therefore the however the construction was done in 2008. Based on this isolated fact the PCIT observed that the claim of deduction has been allowed erroneously by the ld. AO. 3.3] In this regards it is subm ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... py of saudachitti dated 20.03.2006 is attaching herewith for your perusal. We have been calculated cost of property Rs. 60,53,614/- on the basis of index value from the FY 1980-81, because this is our ancestral property which is received us from our fore-parents, hence we considered market value of agriculture land which around kabirkhedi in 1980-81 was around 1,50,000/- par bigha in 1980-81, as per your requirement we have been taken cost of registrar office and as per index cost value were calculate about 92,000/- per bigha, here we are requesting you to consider value of Rs. 1,50,000/- per bigha because land which is subjected to scrutiny is close to indore city as compared land of ShriSarabdinn S/o sarjuji which was mentioned in index, further value of land which is subject matter is a irrigated agriculture land which is reflecting from registry documents itself. We are claiming deduction of section 54 for residential house property which we have been constructed for use of our resident out of consideration received from sale of land, being assessee is a agriculturist and not having awareness and understanding of the law and also usually rural resident neither collecting bill e ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... venue. 13. Before going into facts of the case we will like to go through provisions of section 263 of the Act and some settled judicial precedence. Section 263: "263. Revision of orders prejudicial to revenue.--(1) The Commissioner may call for and examine the record of any proceeding under this Act, and if he considers that any order passed therein by the Assessing Officer is erroneous in so far as it is prejudicial to the interest of the revenue, he may, after giving the assessee an opportunity of being heard and after making or causing to be made such inquiry as he deems necessary, pass such order thereon as the circumstances of the case justify, including an order enhancing or modifying the assessment, or cancelling the assessment and directing a fresh assessment. Explanation.--For the removal of doubts, it is hereby declared that, for the purposes of this sub-section,-- (a) an order passed on or before or after the 1st day of June, 1988 by the Assessing Officer shall include-- (i) an order of assessment made by the Assistant Commissioner or Deputy Commissioner or the Income Tax Officer on the basis of the directions issued by the Joint Commissioner under Section 144-A ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... phrase 'prejudicial to the interests of the revenue 'has to be read in conjunction with an erroneous order passed by the Assessing Officer. Every loss of revenue as a consequence of an order of the Assessing Officer cannot be treated as prejudicial to the interests of the revenue, for example, when an ITO adopted one of the courses permissible in law and it has resulted in loss of revenue; or where two views are possible and the ITO has taken one view with which the Commissioner does not agree, it cannot be treated as an erroneous order prejudicial to the interests of the revenue unless the view taken by the ITO is unsustainable in law. It has been held by this Court that where a sum not earned by a person is assessed as income in his hands on his so offering, the order passed by the Assessing Officer accepting the same as such will be erroneous and prejudicial to the interests of the revenue - Rampyari Devi Saraogi v. CIT [1968167ITR 84 (SC) and in Smt. Tara Devi Aggarwal v. CIT [1973] 88 ITR 323 (SC)". [ Emphasis Supplied ] 15. Hon'ble Apex Court in the case of CIT Vs Max India Limited as reported in 295 ITR 0282 has held that: " 2. At this stage we may clarify tha ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nough. What was the sequitur or consequence of such order qua prejudicial to the interest of the Revenue should have been focused upon. That having not been done, in our considered opinion, exercise of jurisdiction under s. 263 of the Act is totally erroneous and cannot withstand scrutiny. Hence, the Tribunal has correctly unsettled and dislodged the order of the CIT. [ Emphasis supplied ] 17. In the light of the provisions of section 263 of the Act and a settled position of law, powers u/s 263 of the Act can be exercised by the Pr. Commissioner/Commissioner on satisfaction of twin conditions, i.e., the assessment order should be erroneous and also prejudicial to the interest of the Revenue. By 'erroneous' is meant contrary to law. Thus, this power cannot be exercised unless the Commissioner is able to establish that the order of the Assessing Officer is erroneous and prejudicial to the interest of the Revenue. Thus, where there are two possible views and the Assessing Officer has taken one of the possible views, no action to exercise powers of revision can arise, nor can revisional power be exercised for directing a fuller enquiry to find out if the view taken is erron ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ify. The twin requirements of the section are manifestly for a purpose. Merely because the CIT considers on examination of the record that the order has been erroneously passed so as to prejudice the interest of the Revenue will not suffice. The assessee must be called, his explanation sought for and examined by the CIT and thereafter if the CIT still feels that the order is erroneous and prejudicial to the interest of the Revenue, the CIT may pass revisional orders. If, on the other hand, the CIT is satisfied, after hearing the assessee, that the orders are not erroneous and prejudicial to the interest of the Revenue, he may choose not to exercise his power of revision. This is for the reason that if a query is raised during the course of scrutiny by the AO, which was answered to the satisfaction of the AO, but neither the query nor the answer were reflected in the assessment order, this would not by itself lead to the conclusion that the order of the AO called for interference and revision. In the instant case, for example, the CIT has observed in the order passed by him that the assessee has not filed certain documents on the record at the time of assessment. Assuming it to be s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ified in adopting the sale consideration as on the date of agreement to sale and he ought to have applied the value of property u/s 50C of the Act as on the date of registered sale deed. 21. We further note that all the above said information were called by the Ld. AO after issuing notice u/s 148 of the Act on receiving specific information from AIR about the transaction of sale of immovable property. All documents pertaining to agreement to sale, registered sale deed and other documents in support of the transaction and deduction u/s 54 of the Act were called for and duly filed by the assessee. It is not in dispute that the sale consideration mentioned in the agreement to sale was received through banking channels much prior to the date of entering the registered sale deed. It has been consistently held by various coordinate benches that under the given facts and circumstances, date of agreement for sale ( and not the date of registered sale deed) is to be considered for determination of value as per section 50C of the Income Tax Act. Few of such decisions are mentioned below: S.No Citation Reference 1 ACIT vs M/s Balmer Lawrie Van Leer Ltd ITA No 4361/Mum/2016 dt 20-11 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ri Mohan Das Tandon (HUF) 169 ITD 639 (All) 4 M/s Jai Laxmi Developers (P) Ltd Vs DCIT ITA No 5578/ Del/ 2014 dt 5 SmtKundanbenAmbhai Shah V. ITO ITA No 3354/ Ahd/ 2014 dt 30-11-2017 24. In the light of the above settled judicial precedence and the facts of the case, it is clearly discernable that in the instant case where the payment for sale consideration mentioned in the agreement to sale has been duly received through banking channels prior to entering registered sale deed, the value of sale consideration to be adopted in these cases has to be valued as per the Stamp Valuation Authority provided u/s 50C of the Act as on the date of entering the agreement of sale or consideration mentioned in the agreement to sale whichever amount is higher. 25. In view of the above decisions and the facts of the instant appeal we note that Ld. AO after making necessary enquiry has adopted one of the permissible view by accepting the claim of the assessee of computing the capital gain by taking sale consideration as on the date of agreement to sale which thus leaves no room for Ld. Pr. CIT to assume jurisdiction on this particular issue. This common issue covers appeals in the case ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ees received their shares of sale consideration through banking channels within few months of entering the sale agreement. The amount so released was utilized by the assessee towards purchase of new agricultural land. Though the sale agreement was registered on 11.04.2008 but the nexus of investment in new agricultural land is from the sale consideration received from sale of land. Under similar set of facts Coordinate Bench, Jaipur in the case of Smt. Rukmani Devi Agrawal vs. ITO [ITANo.557/JP/2018] dated 18.09.2018 observing as follows: "6.2 The requirement for availing the benefit of Section 54B is to use the capital gain for purchase of new agricultural land and if the assessee does not receive the sale consideration then the question of purchasing new agricultural land does not arise and the very object of Section 54B of the Act would be defeated. Hence the receipt of compensation and payment of consideration for purchase of new asset are the relevant dates for determining the conditions of Section 54B of the Act are satisfied. In the case in hand, when the assessee has received the compensation prior to the payment of the purchase consideration for acquisition of new agricu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of section 54F of the Act, so as to fulfill the very object of section 54B of the Act for which it has been created in the act. This view was adopted by the Ld. AO to allow the deduction u/s 54B of the Act which is legally permissible view and thus, cannot be taken as a basis to assume jurisdiction u/s 263 of the Act and holding the orders of Ld. AO as erronous. In view of this the grounds of appeal raised in the case of Subhash Mukati (ITANo.425/Ind/2018) also deserves to be allowed and proceedings u/s 263 of the Act are directed to be quashed. 31. As regards the remaining 5 appeals in ITANo.870 to 874 apart from the two common issues adjudicate above which gave rise to the proceedings u/s 263 of the Act there was one issue which pertained to the allowability of deduction u/s 54F of the Act. This deduction was claimed by the assessee towards amount utilized for construction of residential house from the sale proceeds of impugned immovable property. Records shows that the assessee(s) have filed necessary documentary evidences such an affidavit in support of construction of new house, withdrawal of amount from bank for construction purpose, physical existence of new residential ho ..... X X X X Extracts X X X X X X X X Extracts X X X X
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