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    <title>2022 (5) TMI 1173 - ITAT LUCKNOW</title>
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    <description>Revision under section 263 was held unsustainable where the assessee had substantiated that the land was agricultural by revenue records, khasra girdawari, jamabandi, a tehsildar&#039;s certificate and other evidence of cultivation and rural location. The Assessing Officer had examined the exempt-income claim in scrutiny as well as rectification proceedings and accepted it after verification, so the view taken was a permissible one. The revisionary authority&#039;s reliance on the sale deed, the buyer&#039;s nature and a prior year&#039;s treatment did not displace the evidence already on record. The assessment was neither erroneous nor prejudicial to the interests of the Revenue, and revision failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=422913</link>
      <description>Revision under section 263 was held unsustainable where the assessee had substantiated that the land was agricultural by revenue records, khasra girdawari, jamabandi, a tehsildar&#039;s certificate and other evidence of cultivation and rural location. The Assessing Officer had examined the exempt-income claim in scrutiny as well as rectification proceedings and accepted it after verification, so the view taken was a permissible one. The revisionary authority&#039;s reliance on the sale deed, the buyer&#039;s nature and a prior year&#039;s treatment did not displace the evidence already on record. The assessment was neither erroneous nor prejudicial to the interests of the Revenue, and revision failed.</description>
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