G.D. Agarwal, A.M. - (1.) THIS appeal by the assessee is directed against the order of CIT(A) IX, Mumbai.
(2.) By way of ground No. 1, the assessee has challenged the validity of the assessment order. However, at the time of hearing before us, this ground of appeal was not pressed. Accordingly, this ground is rejected. Ground No. 2 is against the denial of deduction under Section 54F claimed by the assessee at Rs. 63,17,795. Ground No. 3 is only an argument in support of ground No. 2 whereby the assessee contends that the CIT(A) confirmed the disallowance on a ground totally different than the ground taken by the AO, that too, without giving an opportunity to the assessee for meeting that new ground. Ground No. 4 is against the action of the AO whereby the AO has set off long-term capital loss against long-term capital gains, while the assessee has set off the long-term capital loss against short-term capital gains.
(3.) SINCE all the above three grounds are intricately connected with each other, they are being considered together.;