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    <title>2026 (9) TMI 1253 - ITAT AHMEDABAD</title>
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    <description>Section 54B exemption for reinvestment in agricultural land was allowable where a co-owner&#039;s identical claim, based on the same sale and reinvestment, had been accepted in reassessment; the corresponding claim could not be denied for either assessment year. Agricultural income could not be newly assessed as income from other sources at appellate stage where the original assessment had not addressed that taxability and no notice of enhancement under section 251(2) was issued. The additions were unsustainable and excluded from taxable income.</description>
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      <description>Section 54B exemption for reinvestment in agricultural land was allowable where a co-owner&#039;s identical claim, based on the same sale and reinvestment, had been accepted in reassessment; the corresponding claim could not be denied for either assessment year. Agricultural income could not be newly assessed as income from other sources at appellate stage where the original assessment had not addressed that taxability and no notice of enhancement under section 251(2) was issued. The additions were unsustainable and excluded from taxable income.</description>
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