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The ITAT allowed the assessee's appeal, directing the AO to adopt the enhanced FMV of Rs. 5,00,000 per acre for computation of capital gains and to recalibrate tax relief accordingly; the tribunal held that the AO erred in relying on the earlier FMV of Rs. 3,50,000. The ITAT also held that exclusion from exemption under s.54F(4) was inapplicable where the assessee invested the sums in construction of a residential property within the relevant period and maintained the funds in a nationalized bank pending disbursement, notwithstanding non-deposit in the CGAS and earlier allowance under s.54B. Deduction under section 54F was accordingly allowed.