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INCOME TAX APPELLATE TRIBUNAL (HYDERABAD BENCH)
VIJAY PAL RAO, Vice-President, MANJUNATHA G, Accountant Member
Ashok Manshukla Doshi – Appellant
Versus
Income Tax Officer – Respondent
| Table of Content |
|---|
| 1. facts of sale, purchase, and denied section 54b exemption. (Para 2 , 3 , 4 , 5) |
| 2. parties' arguments on proof of agricultural operations. (Para 8 , 9 , 10) |
| 3. land classification and section 54b conditions analyzed. (Para 11 , 12 , 13) |
| 4. exemption allowed via indirect evidence of use. (Para 14 , 15) |
ORDER
PER MANJUNATHA G., A.M :
This appeal filed by the assessee is directed against the order of the learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre [in short “NFAC”], Delhi, dated 08.07.2025, pertaining to the assessment year 2022-23.
2. The grounds raised by the assessee read as under:
“1. The order of the Learned First Appellate Authority in not correct either on facts or in law and in both.
2. The Learned First Appellate Authority is not justified in confirming the action of assessing officer disallowing a sum of Rs. 9,72,68,001/- being the exemption claimed by the appellant under section 54B of the Income- tax Act.
3. The Learned First Appellate Authority failed to appreciate the fact that the land sold by the appellant is agricultural in nature evidenced by the relevant documents filed and the investment made is in agricultural land suppor
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