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TMI Blog2024 (3) TMI 947X X X X Extracts X X X X X X X X Extracts X X X X ..... Y, J.M: Aggrieved by the final assessment order dated 10/11/2023 passed consequent to the directions of Hon'ble Dispute Resolution Panel, Bengaluru ("DRP"), in the case of Shri Adil Rehman ("the assessee") for the assessment year 2014-15, under section 147 r.w.s. 144C(13) of the Income Tax Act, 1961 (for short "the Act"), assessee filed this appeal. 2. Brief facts of the case are that while ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ceipts, postal charges receipts, conveyance charges, lawyer fees, photocopying expenses. 3. Assessee preferred objections before the learned DRP and submitted that all the expenses incurred by the assessee in connection with transfer are allowable expenditure and relied upon by the decision of the Hon'ble Bombay High Court in the case of CIT vs. Shakuntala Kantilal (1991) 190 ITR 56 (BOM). 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed DR placed reliance on the provisions of section 48 of the Act and submitted that the expenditure incurred for air fare, hotel accommodation etc., cannot be capitalized for the purpose of computing the cost of acquisition and cannot be allowed as allowable expenditure. 7. We have gone through the record in the light of the submissions made on either side. It is not the case of Revenue that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nsfer will be an expenditure covered by section 48(i) of the Act. 8. In the case on hand, the assessee is a non-resident individual and for the purpose of effecting transfer of the property, he had to travel to India and incurred the expenditure for obtaining special power of attorney from Indian Consulate in USA, air tickets, hotel accommodation receipts, postal charges receipts, conveyance char ..... X X X X Extracts X X X X X X X X Extracts X X X X
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