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Whether, on the facts and in the circumstances of the case, the Tribunal was right in law in holding that the land sold by the appellant would not fall within the meaning of Section 2(14)(iii) of the Income Tax Act, 1961, to substantiate the claim that no capital gains would arise therefrom?

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Section 271(1)(c) of the Income Tax Act, 1961 — Penalty — Concealment Penalty — AO would clearly show that there was an agreement with third parties for converting the land into housing plots by an agreement with third parties for converting the land into Housing plots by filling sand, leveling, forming roads, carrying out other development activities, therefore, when the penalty proceedings were initiated, the AO was fully justified in holding that the assessee was consciously aware of the real position knowingly furnished inaccurate particulars of income in the revised return, therefore, the levy of penalty was justified — Chemmancherry Estates Company vs. Commissioner of income tax [2019] 417 ITR 314 (Madras)

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