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The learned Authorised Representative inviting attention to the paper book filed submitted that in the facts the present case the assessee is challenging the jurisdiction of the AO in reopening the case beyond the period of 4 years. Referring to the provisions of law it was his submission that in the facts the present case the reopening has been done beyond the stipulated period of 4 years.

Shanti Prime Publication Pvt. Ltd.

Section 54 & 147 of the Income Tax Act, 1961 — Capital gains — Reopening beyond four years was not sustainable as assessee invested the amount received on sale of original asset in fixed deposit, acquisition of new residential house by making payment by issue of cheque on his account in another bank was rightly allowed deduction under section 54—Keshav Dutt Shreedhar vs. Deputy Commissioner of income tax [2019] 202  TTJ 117 (Chandigarh)

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