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TNMM Segmentation Limits Transfer-Pricing Adjustments to Associated-Enterprise Transactions and Requires Turnover-Based Comparable Selection for IT Se...
The ITAT quashed the order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The assessee was eligible for deduction u/s 54EC as the land was used for agricultural purposes in the preceding two years before its sale, as evident from the 7/12 extracts. The ITAT held that the Assessing Officer's conclusion accepting the assessee's claim was reasonable and not erroneous, and the PCIT failed to establish that the order was prejudicial to the Revenue's interests. The reference to the Valuation Officer was not mandatory, and the PCIT lacked authority to direct such a reference. The ITAT ruled in favor of the assessee, allowing the grounds raised.
The ITAT quashed the order passed by the Principal Commissioner of Income Tax (PCIT) u/s 263 of the Income Tax Act. The assessee was eligible for deduction u/s 54EC as the land was used for agricultural purposes in the preceding two years before its sale, as evident from the 7/12 extracts. The ITAT held that the Assessing Officer's conclusion accepting the assessee's claim was reasonable and not erroneous, and the PCIT failed to establish that the order was prejudicial to the Revenue's interests. The reference to the Valuation Officer was not mandatory, and the PCIT lacked authority to direct such a reference. The ITAT ruled in favor of the assessee, allowing the grounds raised.
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