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    <title>2026 (1) TMI 181 - ITAT PUNE</title>
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    <description>Taxability of receipts from transfer of development rights and the claimed exemption under section 96 of the land acquisition law could not be decided on the existing record because the Assessing Officer had not examined the claim on a complete factual foundation and the supporting material was incomplete. Verification of the land cost, the nature of the acquisition, the book treatment of the land/TDR transaction, and satisfaction of the statutory exemption conditions remained pending. The matter was therefore remitted for fresh adjudication, with the jurisdictional Assessing Officer directed to reconsider the exemption claim and related tax treatment after giving a reasonable opportunity of hearing. No final finding was recorded on the merits.</description>
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      <title>2026 (1) TMI 181 - ITAT PUNE</title>
      <link>https://www.taxtmi.com/caselaws?id=784425</link>
      <description>Taxability of receipts from transfer of development rights and the claimed exemption under section 96 of the land acquisition law could not be decided on the existing record because the Assessing Officer had not examined the claim on a complete factual foundation and the supporting material was incomplete. Verification of the land cost, the nature of the acquisition, the book treatment of the land/TDR transaction, and satisfaction of the statutory exemption conditions remained pending. The matter was therefore remitted for fresh adjudication, with the jurisdictional Assessing Officer directed to reconsider the exemption claim and related tax treatment after giving a reasonable opportunity of hearing. No final finding was recorded on the merits.</description>
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