The assessee-HUF sold agricultural land for Rs. 33.82 crores, claiming a deduction of Rs. 17.75 crores under section 54B for the purchase of other agricultural land. The AO accepted the income after a thorough inquiry, including documentary evidence such as sale deeds and bills. However, the PCIT set aside the assessment, citing a lack of cross-verification with the agriculture department and previous non-declared agricultural income. On appeal, the Tribunal quashed the PCIT’s order, concluding that the AO had reasonably determined the transaction as capital gains eligible for deduction, and that both conditions under section 263 were not met. The revenue’s appeal was dismissed as no substantial question of law arose, and the treatment of capital gains for a co-owner corroborated the AO’s position.(AY. 2016-17)