TMI Blog2022 (8) TMI 158X X X X Extracts X X X X X X X X Extracts X X X X ..... asons were not supplied to the assessee by reopening the case but since the very basis of reopening was related to the urban land, the assessee was very much aware about the reasons upon which the reopening was made by the Revenue Authorities. Thus, the reopening is valid which is also reiterated by the CIT(A) in paragraph of the order of the CIT(A). Hence ground are dismissed. Lands at Vastrapur and Rancharda were coming under the definition of urban land under section 2(ea)(v) of the Wealth Tax Act as the documents which were produced before the Revenue Authorities and before us clearly does not state that this are agricultural land. The assessee contended that these are agricultural land as per the records of the Government but only d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... produced by the appellant. 1.3 The Ld. AO has grossly erred in making addition without passing a speaking and reasoned order. The appellant should therefore be allowed to produce additional evidence during the course of appellate proceedings and should be admitted. 2. The Ld. AO has grossly erred in law and on facts on holding agricultural lands at Vastrapur and Ranchanrda as urban land u/s 2(ea)(v) of WT Act and thereby making addition of Rs.2,12,98,200/-. The Ld. CIT(A) ought to have considered the fact that the urban land at Vastrapur and Rancharda is an agricultural land as per the records of Government and is used for agricultural purposes. The Ld. CIT(A) ought to have taken into consideration amendment brought in by Fianc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e assessee as per the contentions of the assessee. During the course of assessment proceedings, the assessee submitted that both the said lands were non-urban land and as such exempt under Section 2(ea)(v) of Wealth Tax Act. The Assessing Officer concluded that the said lands were urban land and as such its value aggregating to Rs.2,12,98,200/- was brought to tax. 4. Being aggrieved by the assessment order, the assessee filed appeal before the CIT(A). The CIT(A )dismissed the appeal of the assessee. 5. The Ld. AR submitted that the land situated at Vastrapur and Rancharda were non-urban land and the assessee has given all the evidences before the Assessing Officer which were ignored by the Assessing Officer as well as the CIT(A). The ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... y reopening the case but since the very basis of reopening was related to the urban land, the assessee was very much aware about the reasons upon which the reopening was made by the Revenue Authorities. Thus, the reopening is valid which is also reiterated by the CIT(A) in paragraph no.4.4 of the order of the CIT(A). Hence ground nos.1.1, 1.2 1.3 are dismissed. 8. As regards ground no.2 related to the merits, it is seen that the lands at Vastrapur and Rancharda were coming under the definition of urban land under section 2(ea)(v) of the Wealth Tax Act as the documents which were produced before the Revenue Authorities and before us clearly does not state that this are agricultural land. The assessee contended that these are agricultura ..... X X X X Extracts X X X X X X X X Extracts X X X X
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