PRAKASH CHANDRA MUKHERJEE,JAMSHEDPUR vs. ITO, WARD-2(1), JAMSHEDPUR

ITA 317/RAN/2025Status: DisposedITAT Ranchi10 September 20267 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the proviso to Section 50C, which allows for the adoption of agreement value under certain conditions, cannot be applied retrospectively to the assessment year 2013-14. Therefore, the addition made by the Assessing Officer was upheld.

What were the facts?

The assessee sold a plot of land for ₹50,00,000, while the government's circle rate was ₹1,08,90,000. The Assessing Officer reopened the case and added the difference of ₹58,90,000 as income under Section 50C.

What were the issues?

Whether the proviso to Section 50C, introduced for a later assessment year, can be applied retrospectively to the assessment year 2013-14. Whether the addition based on the difference between sale consideration and stamp duty valuation is justified.

Which sections of the Income-tax Act were involved?

Section 50C,Section 147,Section 148

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, RANCHI BENCH, RANCHI

Before: SHRI RATNESH NANDAN SAHAY & SMT. RAJANI GUDURI

For Appellant: Shri P.K. Barman, C.A
For Respondent: Shri Ram Chandra Marndi, Sr.DR
Hearing: 24/08/2026Pronounced: 10/09/2026

PER: BENCH

1.

This appeal by the assessee is directed against the order of the ld. Addl/JCIT(A)-4, Mumbai [in short, the ld. CIT(A)] dated 29/07/2025 for the Assessment Year (AY) 2013-14. 2. Facts of the case, in brief, are that the assessee has earned income from sale of building materials, house property and capital gains. During the assessment year under consideration, the Assessing Officer received information that the assessee has sold a plot of land to M/s Bravo Sponge Iron Ltd. on 30/03/2013 for a sale consideration of ₹ 50,00,000/- whereas the circle rate fixe

The order continues below.

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