Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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Exemption under section 54B requires proof of actual agricultural use of the land during the prescribed period; mere classification in revenue records is insufficient. The Tribunal found that revised 7/12 extracts could only raise a presumption and were not conclusive without corroborative evidence such as produce sale bills, seed or fertiliser purchase records, labour records, or other material showing active cultivation. As no such evidence was produced, the essential statutory condition remained unproved and the denial of exemption was upheld, with the addition sustained. The Tribunal also distinguished the cited contrary precedent on facts and relied on authority holding that revenue entries alone do not establish agricultural use.
Exemption under section 54B requires proof of actual agricultural use of the land during the prescribed period; mere classification in revenue records is insufficient. The Tribunal found that revised 7/12 extracts could only raise a presumption and were not conclusive without corroborative evidence such as produce sale bills, seed or fertiliser purchase records, labour records, or other material showing active cultivation. As no such evidence was produced, the essential statutory condition remained unproved and the denial of exemption was upheld, with the addition sustained. The Tribunal also distinguished the cited contrary precedent on facts and relied on authority holding that revenue entries alone do not establish agricultural use.
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