Extended limitation requires willful misstatement or suppression with intent to evade; mere misclassification does not sustain confiscation or penalty...
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Capital gains computation under section 50C: the property is recorded as agricultural/residential in revenue records, so circle rate characterisation must follow those records and the multiplicative factor of 1 applies even though the building was used commercially without sanction; deemed conversion cannot be presumed from unauthorized use until recognised by revenue authorities, so the assessing officer's application of factor 3 was contrary to revenue records and invalid, and the appellate authority's direction to apply factor 1 was affirmed by ITAT, resulting in the decision against the revenue.
Capital gains computation under section 50C: the property is recorded as agricultural/residential in revenue records, so circle rate characterisation must follow those records and the multiplicative factor of 1 applies even though the building was used commercially without sanction; deemed conversion cannot be presumed from unauthorized use until recognised by revenue authorities, so the assessing officer's application of factor 3 was contrary to revenue records and invalid, and the appellate authority's direction to apply factor 1 was affirmed by ITAT, resulting in the decision against the revenue.
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