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TMI Blog2024 (5) TMI 490X X X X Extracts X X X X X X X X Extracts X X X X ..... g differential amount nowhere 10% of the actual sale price as per sec. 56(2)(vii)(b) 3rd proviso adopting the tolerance margin given in sec. 50C(1) 3rd proviso mutatis mutandis . As argued that the tolerance margin of 10% in sec. 50C(1) 3rd proviso substituting 5% by the Finance Act, 2020 is applicable w.e.f. 01.04.2021 whereas the impugned assessment year herein is 2014-2015. No merit in the Reve ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... file perused. 2. The assessee pleads the following substantive grounds in the instant appeal : 1. The assessee has filed return of income for the A.Y. 2014- 15 on 31/03/2015 declaring total income at Rs. 7,42,010/- and regular assessment u/s 143(3) has been completed on a total income of Rs. 14,11,110/- by The Income Tax Officer ward 1(1), Nagpur, vide order dated 26/12/2016. 2. The assessee is in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1961. 3. The assessee during course of scrutiny assessment has submitted the copy of sale deeds of the two agricultural lands, however the A.O. has not accepted the contention of the assessee that the said properties are agricultural lands and not a capital asset and the provisions of section 56(2)(vii) of the Income Tax Act, 1961 are not applicable in the said transactions and treated the same a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ted 26.12.2016 as upheld in the NFAC s lower appellate order. 4. It transpires during the course of hearing that the assessee had purchased his former capital asset at Mouza Khapa (Khurd), Tehsil-Hingana, Dist. Nagpur for Rs. 69.25 lakhs followed by stamp valuation thereof of Rs. 70.86 lakhs resulting in the differential addition amount of Rs. 1,61,000/-. His latter capital asset is at Mouza-Neri ..... X X X X Extracts X X X X X X X X Extracts X X X X
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