2025 (6) TMI 386

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.... ORDER PER SANJAY GARG, JUDICIAL MEMBER: The present appeal has been filed by the Assessee against the order passed under section 263 by the Principal Commissioner of Income Tax, Ahmedabad-1 [hereinafter referred to as "PCIT"] dated 04.03.2024 arising from the order passed u/s. 147 of the Income Tax Act, 1961 (here-in-after referred to as "the Act") relevant to the Assessment Year 2017-18. ....

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.... in question was falling within the municipality limits of Ahmedabad and further the same was not an agricultural land. On being show-caused in this respect, the assessee explained that land was situated about 14.5 kilometers from the municipality limits. The ld. PCIT did not dispute or deliberate upon the issue as to whether the land was situated outside municipality limits, however he held that ....

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....nition of agricultural land or not as per the provisions of section 2(14) of the Act. The ld. Departmental Representative has pointed out that as per the reports, during the year under consideration when the sale was of land was made, there was no agricultural activity carried out on the said land, therefore, the ld. PCIT was justified in exercising his revision jurisdiction u/s. 263 of the Income....