THE INDIAN SALT MANUFACTURERS ASSOCIATION,MUMBAI vs. DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-2(1), MUMBAI

ITA 4431/MUM/2026Status: DisposedITAT Mumbai14 August 2026AY 2023-2414 pages
AI SummaryAllowed

What were the facts?

A charitable trust sold an immovable property for Rs. 1,50,00,000, which was approved by the Charity Commissioner. The Assessing Officer invoked Section 50C and used the stamp duty value of Rs. 2,47,62,496 as the sale consideration, leading to a higher capital gains calculation. The assessee appealed this decision.

What did the Tribunal hold?

The Tribunal held that the sale consideration approved by the Charity Commissioner, a statutory authority, should be considered, not the stamp duty value under Section 50C. The Tribunal also directed the allowance of certain expenses that were not properly disallowed by the Assessing Officer.

What were the issues?

Whether the stamp duty value under Section 50C can override the sale consideration approved by the Charity Commissioner for a charitable trust, and whether expenses disallowed without proper reasoning are valid.

Which sections of the Income-tax Act were involved?

Section 50C,Section 11(1A),Section 234B,Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “C” BENCH, MUMBAI

Before: SHRI CHALLA NAGENDRA PRASAD & SHRI G. M. DOSS

For Respondent: Shri. Ajay Soneji, Sr. DR
Pronounced: 14.08.2026

PER G.M. DOSS, ACCOUNTANT MEMBER :

This appeal has been preferred by the assessee against the order dated 20.02.2026 passed by the learned Commissioner of Income-tax (Appeals), National Faceless Appeal Centre, Delhi [hereinafter referred to as the “ld. CIT(A)”], under section 250 of the Income-tax Act, 1961 (hereinafter referred to as “the Act”), for the Assessment Year 2023-24. Grounds of Appeal

2.

The assessee has raised the following grounds of appeal:

1 The Indian Salt Manufacturers Association

Ground No. 1 “On the facts and i

The order continues below.

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