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ITAT held that the subject lands qualify as agricultural lands under section 2(14)(iii)(b), exempting them from long-term capital gains taxation. The tribunal considered evidence including Patta certificates, Chitta Adangal, and revenue records demonstrating agricultural classification. Referencing prior Madras HC precedents, the tribunal affirmed land's agricultural status based on official documentation, irrespective of actual cultivation. Consequently, the tribunal set aside the CIT(A)'s order confirming capital gains addition and allowed the assessee's appeal. Additionally, regarding section 14A disallowance, the tribunal directed the Assessing Officer to restrict disallowance proportionate to the exempt income earned during the relevant previous year.
ITAT held that the subject lands qualify as agricultural lands under section 2(14)(iii)(b), exempting them from long-term capital gains taxation. The tribunal considered evidence including Patta certificates, Chitta Adangal, and revenue records demonstrating agricultural classification. Referencing prior Madras HC precedents, the tribunal affirmed land's agricultural status based on official documentation, irrespective of actual cultivation. Consequently, the tribunal set aside the CIT(A)'s order confirming capital gains addition and allowed the assessee's appeal. Additionally, regarding section 14A disallowance, the tribunal directed the Assessing Officer to restrict disallowance proportionate to the exempt income earned during the relevant previous year.
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