No penalty on disallowance of Deduction U/s. 54B claimed under a bona fide belief

Nitinkumar Desai Vs ACIT (ITAT Ahmedabad)  The case of the assessee is that he has made investment in Gota land to the extent of Rs. 1,09,82,400/-. This investment was made by the assessee within two years of sale of agriculture land. Thus, case of the assessee was that capital gain arose to him on sale of agriculture land was invested in purchase of agriculture land. According to the assessee he was entitled for deduction under section 54B. The AO has cut short his claim by a sum of Rs.85,67,400/- on the ground that this payment was made after due date of filing of return. Thus, the question...