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The learned C.I.T (A) erred in not accepting the appellant's submission that land sold by him was agricultural in nature and the capital gain on its sale was exempt under section 10 (37) (i) of the I.T. Act in as much as the land was not situated in an area referred to in item (a) of sub clause (iii) of clause (14) of section 2 of the Act.

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Section 147 & 148 of the Income tax Act, 1961 — Reassessment — Information received by the AO from the Investigation Wing about verifying the sources of cash deposits in the assessee—bank account was tangible incriminating material coming to the possession of the AO who rightly applied section 147, therefore, the Reassessments were valid — Anthiah Pancras vs. Income Tax Officer [2019] 76 ITR (trib) 50 (Chennai)

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