Revision u/s 263 - Sure, the AO having not considered this aspect of the matter at all, there was no...

Revision u/s 263 - Sure, the AO having not considered this aspect of the matter at all, there was no occasion for the assessee to clarify anything thereto, much less qua the date of transfer, which forms the fulcrum of his case/s. It does not, however, lie in the mouth of the assessee, who “explained” the source of the investment in property purchased during the year, to contend that the date of the said purchase falls in the immediately preceding year i.e., in the facts and circumstances of the case and the law in the matter. - Revision proceedings sustained - AT .....

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