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    <title>2025 (9) TMI 1763 - ITAT SURAT</title>
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    <description>Land recorded as agricultural in revenue records with past agricultural user and no owner-driven conversion retains rural agricultural character for exclusion from capital asset under Section 2(14)(iii); consequent addition of Rs. 1,21,92,898 was deleted. Because the foundational assessment addition was set aside, penalty proceedings under Section 270A(8) read with 270A(9) lacked basis and were quashed. Multiple statutory notices and the assessee&#039;s responses were considered and found to afford opportunity to be heard; no breach of principles of natural justice was found, and that ground was dismissed.</description>
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      <description>Land recorded as agricultural in revenue records with past agricultural user and no owner-driven conversion retains rural agricultural character for exclusion from capital asset under Section 2(14)(iii); consequent addition of Rs. 1,21,92,898 was deleted. Because the foundational assessment addition was set aside, penalty proceedings under Section 270A(8) read with 270A(9) lacked basis and were quashed. Multiple statutory notices and the assessee&#039;s responses were considered and found to afford opportunity to be heard; no breach of principles of natural justice was found, and that ground was dismissed.</description>
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