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Whether on facts and in law, the Tribunal has substantially erred in law in confirming disallowance of Rs. 14,78,092/- u/s.54B for the year under consideration ?

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Section 45 of the Income Tax Act, 1961 — Capital gains — The legislative intent as can be gathered from sections 54 to 54B is that upon Capital gains arising and in the event of the consideration or gains are invested and kept in for a lock in period, the assessee would get the benefit and not otherwise, therefore, exemption granted to assessee was rightly withdrawn. assessee dilfer new asset of agricultural land within lock in period of three years — Hitesh Mansukhlal Bagdai vs. Assistant Commissioner of income tax [2019] 419 ITR 276 (Gujarat)

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