Section 54B relief requires a valid transfer, while a fresh factual claim about exchanged land justified remand.

For section 54B, relief could not be sustained on an unregistered transfer arrangement for agricultural land, because the Tribunal read "transfer" with section 2(47) and applied the Supreme Court's ruling in Balbir Singh Maini to reject reliance on earlier contrary decisions. It also noted that a later affidavit and legal notices raised a fresh factual question whether the land exchanged by the assessee was Government land. That issue required verification by the Assessing Officer, so the matter was remanded for fresh examination of the exchanged land's nature and validity.

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Issues: Whether deduction under section 54B could be denied for purchase of agricultural land on the ground that the title deed was unregistered, and whether the subsequent plea that the land exchanged by the assessee was Government land required fresh verification.

Analysis: The term "transfer" in section 54B was read in the context of section 2(47) of the Income-tax Act, 1961, and the Tribunal held that purchase of immovable property forms part of the broader transfer framework. On that basis, it rejected the contention that section 54B relief can be claimed even without a valid title document or registered conveyance, and it held that the reliance on earlier decisions could not prevail over the Supreme Court's ruling in Balbir Singh Maini. At the same time, the Tribunal noted the assessee's later affidavit and legal notices suggesting that the land given in exchange may have been Government land, which raised a factual issue requiring verification by the Assessing Officer.

Conclusion: The objection to deduction under section 54B on the ground of absence of registration was rejected, but the matter was remanded for verification of the newly raised claim regarding the nature and validity of the exchanged land.

Final Conclusion: The assessee obtained only partial relief, and the assessment issue was sent back for fresh adjudication after examining the subsequent factual development.

Ratio Decidendi: For section 54B, entitlement to exemption linked to purchase of agricultural land cannot be sustained on an unregistered transfer arrangement, and a later factual claim affecting the validity of the exchange may justify remand for verification.

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