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Issues: Whether deduction under section 54B of the Income-tax Act, 1961 was allowable on sale of the land and whether the matter required remand for verification of the revenue records.
Analysis: The claim for deduction turned on whether the land sold was used for agricultural purposes during the two years preceding transfer. The assessee relied on girdawari and other revenue records to show cultivation, while the Revenue disputed that the relevant khasra entry was properly reflected and pointed to blanks in the record. As the authenticity and correctness of the documentary evidence were not conclusively verified, the entitlement to deduction could not be finally determined on the existing material.
Conclusion: The matter was remanded to the first appellate authority for verification of the documentary evidence and fresh adjudication after granting the assessee an opportunity to substantiate the claim.