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2022 (1) TMI 982

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..... A) to carry out necessary verification. Assessee is directed to file all relevant documents in respect of purchase of site in support of its claim. CIT(A) is directed to verify all the relevant documents and to consider the claim in accordance with law - Ground raised by assessee stands allowed for statistical purposes. - ITA No.333/Bang/2020 - - - Dated:- 31-8-2021 - Shri Chandra Poojari, Accountant Member And Smt. Beena Pillai, Judicial Member For the Assessee : Shri Suresh Muthukrishnan, Advocate For the Revenue : Shri Kannan Narayanan, JCIT(DR) ORDER PER BEENA PILLAI, JUDICIAL MEMBER Present appeal has been filed by assessee against order dated 13/01/2020 passed by the Ld.CIT(A)-3, Bangalore for .....

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..... d for conversion of the land from agricultural to residential within 2 years of purchase of land. She was issued the land conversion certificate on 27/06/1988. The Ld.AO observed that the land was developed into residential layout of approximately 60 sites after convergent at the sites were sold from 1991 onwards till 2011. The balance 12 sites were sold during financial year relevant to assessment year under consideration. 4. The assessee claimed profit on sale of approximately 12 sites amounting to ₹ 61,00,000/- as long term capital gain, the details of which are as under: Sl.No. Date of Sale Site No Size Name of the Purchaser .....

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..... her denied the exemption claimed by assessee under section 54F due to reclassification of long term capital gains as business income. 7. Aggrieved by the order of Ld.AO, assessee was in appeal before the Ld.CIT(A). 8. The Ld.CIT(A) after considering the submissions of assessee granted the sale proceeds for ₹ 61 Lacs received on sale of 12 plots to be computed as LTCG. However, for considering the claim of exemption under section 54F the Ld.CIT(A) was of the view that assessee did not comply with the requirement of provisions to be eligible to claim deduction under section 54F. 9. Aggrieved by the order of Ld.CIT(A) assessee is in appeal before us now. The only issue that is alleged by the Ld.AR is in respect of denial o .....

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