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2023 (10) TMI 1054 - ITAT AGRARevision u/s 263 - Gain on sale of land - nature of land sold - as per CIT no queries in respect of the nature of land were raised by the AO - HELD THAT:- We find that note to Tehsildar cannot be equated to a certificate. But internet search done by ld. CIT (A) is also not conclusive evidence. Moreover, there is conflicting view as to whether there was a certificate from Tehsildar available or a note to him by the assessee as claimed by ld. CIT (A). Be as it may, it is clear that AO has made an enquiry and taken a plausible view. In these circumstances, we are of the opinion that the AO has made necessary enquiries and it is a plausible view that the land involved is agricultural land. Hence, we are of the opinion that the order of PCIT needs to be set aside and the issue is decided in favour of the assessee.
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