ITO, WARD-2(1), PATNA, PATNA vs. JAIDAYAL PACKAGING PVT. LTD, PATNA

ITA 623/PAT/2024Status: DisposedITAT Patna20 July 2026AY 2013-1423 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that the land sold was indeed rural agricultural land, exempt from capital gains tax, as it was beyond the specified distance from municipal limits as per CBDT notifications. The Tribunal also dismissed the grounds related to speculative loss, finding no material to contradict the CIT(A)'s findings.

What were the facts?

The Revenue appealed the deletion of additions made by the Assessing Officer (AO) regarding profit on sale of rural agricultural land and speculation loss. The AO had disallowed the exemption for agricultural land sale due to insufficient evidence and treated share trading losses as speculative. The CIT(A) had deleted these additions.

What were the issues?

Whether the land sold was a capital asset and whether the losses claimed from share trading were speculative.

Which sections of the Income-tax Act were involved?

Section 2(14),Section 133A,Section 131(1A),Section 143(1),Section 148,Section 142(1),Section 250

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, PATNA BENCH, PATNA

Hearing: 04.06.2026Pronounced: 20.07.2026

PER LAXMI PRASAD SAHU, ACCOUNTANT MEMBER

This is an appeal filed by the Revenue against the order passed u/s 250 of the Income Tax Act, 1961 (hereinafter referred to as “the Act”) by the Ld. Commissioner of Income Tax (Appeals) [hereinafter referred to as “the Ld. CIT(A)] dated 29.08.2024, DIN & order No.

2 Jaidayal Packaging Pvt. Ltd. ITBA/NFAC/S/250/2024-25/1068114536(1) on the following grounds of appeal:

“1. The Ld. CIT (A) has erred in deleting the addition made on account of profit arising on sale of rural agricultural land. The AO in his order has clearly mentioned that despite calling for the records of purchase deed, sale deed, computation o

The order continues below.

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