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2019 (4) TMI 1420 - AT - Income TaxDisallowance made u/s.14A - no show cause notice to the assessee before invoking the provisions - HELD THAT:- In view of the ratio laid down in the case of Godrej & Boyce Manufacturing Company Ltd. Vs. DCIT [2017 (5) TMI 403 - SUPREME COURT OF INDIA] and also the clear cut provisions of the Act, i.e. section 14A(3) of the Act, there is no merit in the disallowance made by the AO without giving any show cause notice to the assessee before invoking the provisions of section 14A of the Act. The disallowance made by the Assessing Officer and confirmed by the CIT(A) is reversed. Grounds of appeal raised by the assessee are thus allowed. Deduction u/s 54B - capital gain on sale of one agricultural land - investment made in two agricultural land - AO allowed dedction in respect of one property - HELD THAT:- There was no ambiguity in the provisions of section 54B, there was no clarification needed to be given. Accordingly, I find no merit in the plea of the assessee that it could claim the aforesaid deduction in respect of two separate investments in agricultural lands, made by the assessee consequent to selling of one agricultural land. In case, the assessee had sold two pieces of land, i.e. agricultural land, then it could claim the deduction against the aforesaid investments in two separate pieces of land. However, in the present case, it is not so. Hence, I find no merit in the plea of the assessee. Ratio of decisions in SMT. SAVITA RANI. [2002 (5) TMI 6 - PUNJAB AND HARYANA HIGH COURT] & Anil Bishnoi Vs. ACIT [2017 (10) TMI 868 - ITAT CHANDIGARH] are not applicable in facts of assessee.
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