RAJENDRA KUMAR GARG,JAIPUR vs. ITO WARD (4)2, JAIPUR

ITA 1209/JPR/2025Status: DisposedITAT Jaipur16 September 2026AY 2010-117 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the deduction under Section 54F cannot be denied based on the nature of the plot or construction, and Section 50C's value cannot be imported into Section 54F calculations. The case was found to be covered by a previous co-ordinate bench decision.

What were the facts?

The assessee claimed capital gains exemption on the sale of agricultural land. The Assessing Officer (AO) treated the land as a capital asset, applied Section 50C, and denied exemption under Section 54F, stating the new construction was a godown. The CIT(A) upheld the AO's order.

What were the issues?

Whether agricultural land outside municipal limits is a capital asset, applicability of Section 50C to Section 54F calculations, and eligibility for deduction under Section 54F for investment in a new asset.

Which sections of the Income-tax Act were involved?

Section 2(14),Section 50C,Section 54F,Section 147,Section 143(3),Section 250,Section 234B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, JAIPUR

Before: Shri T.R. Senthil Kumar & Shri Prakash

PER : PRAKASH, ACCOUNTANT MEMBER:-

1.

This appeal by the Assessee is directed against the order of the learned Commissioner of Income Tax (Appeals) [hereinafter referred to as “the learned CIT(A)”] dated 28.07.2025 passed under section 250 of the In- come Tax Act, 1961 (hereinafter referred to as “the Act”) arising out of the reassessment order dated 26.12.2017 passed by the Assessing Officer (hereinafter referred to as "the AO") under section 147 read with section 143(3) of the Act for the assessment year 2010-11. 2. The grounds of appeal raised by the Assessee before us in the memoran- dum of appeal in Form No. 36 read as under:

I.T.A No. 1209/JPR/2025 Page No 2 Rajendra Kumar Garg

The order continues below.

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