Condonation of Delay denied: communication lapses and corporate restructuring found insufficient; prolonged inaction and lack of bona fides led to ref...
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Official certificates and revenue records admitted by the first appellate authority were treated as properly relied upon because they went to the root of the dispute and no specific prejudice to the Revenue was shown. On the merits, the land was accepted as rural agricultural land on the basis of urban development authority certificates, revenue records and census data showing it lay beyond the prescribed municipal distance. As the Assessing Officer produced no independent verification or conclusive contrary evidence, the lands were held to fall outside section 2(14) and outside section 194-IA, so the assessee could not be treated as an assessee in default under section 201(1) and interest under section 201(1A) was not sustainable.
Official certificates and revenue records admitted by the first appellate authority were treated as properly relied upon because they went to the root of the dispute and no specific prejudice to the Revenue was shown. On the merits, the land was accepted as rural agricultural land on the basis of urban development authority certificates, revenue records and census data showing it lay beyond the prescribed municipal distance. As the Assessing Officer produced no independent verification or conclusive contrary evidence, the lands were held to fall outside section 2(14) and outside section 194-IA, so the assessee could not be treated as an assessee in default under section 201(1) and interest under section 201(1A) was not sustainable.
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