TMI Blog2018 (4) TMI 341X X X X Extracts X X X X X X X X Extracts X X X X ..... Section 260A of the Income Tax Act, 1961 [hereafter "the 1961 Act"], complaining that the deletion of Rs. 69,30,800/- by the lower appellate authorities is contrary to Section 54B of the 1961 Act. The assessment was completed on 19.12.2008; the assessee had reported sale of agricultural land which was acquired for an initial consideration of Rs. 94,88,940/-. The capital gains earned was Rs. 1,62 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... as it amounted to fresh opinion and, therefore, an impermissible review and that, even on the merits, the addition was not justified. The Tribunal followed suit. It is firstly contended that the Tribunal's finding that the Revenue did not urge any ground with respect to the reopening of the assessment is incorrect because a general ground in support of its appeal has been made. It is next conten ..... X X X X Extracts X X X X X X X X Extracts X X X X
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