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    <title>2026 (1) TMI 73 - ITAT DELHI</title>
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    <description>Reassessment under s.147 was upheld as valid since reasons were recorded, requisite approval obtained, statutory notices were duly served, and participation cured any plea of breach of natural justice; the challenge failed. On taxability of gains, the land was held to be a &quot;capital asset&quot; under s.2(14) because the assessee failed to prove it was rural agricultural land: the distance certificate was illegible, no cogent evidence was produced, and the AO correctly relied on the relevant notification showing location within prescribed municipal limits; capital gains were taxable. Deductions under ss.54F and 54B were partly disallowed on factual grounds (including non-compliance with time limits and joint purchase) and, absent additional evidence/Rule 46A, the disallowance was affirmed; appeal dismissed.</description>
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      <title>2026 (1) TMI 73 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=784317</link>
      <description>Reassessment under s.147 was upheld as valid since reasons were recorded, requisite approval obtained, statutory notices were duly served, and participation cured any plea of breach of natural justice; the challenge failed. On taxability of gains, the land was held to be a &quot;capital asset&quot; under s.2(14) because the assessee failed to prove it was rural agricultural land: the distance certificate was illegible, no cogent evidence was produced, and the AO correctly relied on the relevant notification showing location within prescribed municipal limits; capital gains were taxable. Deductions under ss.54F and 54B were partly disallowed on factual grounds (including non-compliance with time limits and joint purchase) and, absent additional evidence/Rule 46A, the disallowance was affirmed; appeal dismissed.</description>
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      <pubDate>Tue, 30 Dec 2025 00:00:00 +0530</pubDate>
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