Held that, when the transfer of agricultural land itself is prohibited under State laws, the alleged agreement would not bring the case in the category of transfer of ownership without any formal deed of title. Hence, the crucial aspect and the very basis of allowability of deduction under S. 54B was not considered by the AO and consequently the revision made by PCIT is valid. (AY. 2011-12)
Ram Charan Meena. v. PCIT (2019) 182 DTR 268 / 201 TTJ 1004 / 73 ITR 568 (Jaipur)(Trib.)
S. 263 : Commissioner-Revision of Orders prejudicial to revenue-Agricultural land claimed to have been purchased by the assessee which is prohibited under Land Reforms Act of State of Rajasthan, not eligible for deduction under section 54B–AO did not consider the crucial basis before allowing deduction-Revision rightly invoked by PCIT. [S. 54B]