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Assessee has raised the ground that under the facts and circumstances of the case the ld. CIT(A) erred in law and fact in confirming the addition of Rs. 25,69,606/- (Rs. 26,27,403 minus relief granted Rs. 57,797) as made by the AO on account of Long Term Capital Gain (''LTCG'' for short) as against Rs. 1,93,215/- declared by the assessee by rejecting the deduction u/s 54F of the Act of Rs. 23,76,391/- as claimed by the assessee. The rejection so made and confirmed by the ld. CIT(A) being totally contrary to the provisions of law and facts of the case, the appellant be held entitled to the deduction u/s 54F as claimed.

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Section 147 of the Income-tax Act, 1961—Reassessment - The objection raised by the assessee regarding the correct amount of capital gain as recorded in the reasons cannot be a ground for quashing the proceedings u/s 147/148 when the AO has shown the relevance between the reasons recorded and the formation of belief on the subject matter and the source of income which has escaped assessment - When the reasons are itself self-explanatory and speaking the link between the material and the formation of belief then the approving authority i.e. Pr. CIT is not required further to supplement the reasons to believe as recorded by the AO. - ARPIT KHAIRARI V/s ITO - [2020] 183 ITD 737 (ITAT-JAIPUR)

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