RAM BHAJ,KHANAURI MANDI vs. INCOME TAX OFFICER, SANGRUR
What did the Tribunal hold?
The Tribunal followed a coordinate bench decision and held that 50% of the interest on enhanced compensation was rightly taxed. For the cash deposit addition, the matter was set aside for de-novo adjudication due to principles of natural justice.
What were the facts?
The assessee received enhanced compensation with interest. The AO taxed 50% of this interest and also made an addition for a cash deposit. The CIT(A) upheld the AO's order.
What were the issues?
The taxability of interest on enhanced compensation and the addition for cash deposit.
Which sections of the Income-tax Act were involved?
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, “SMC” BENCH, CHANDIGARH
IN THE INCOME TAX APPELLATE TRIBUNAL “SMC” BENCH, CHANDIGARH VIRTUAL HEARING HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM आयकरअपीलसं./ ITA No.953/CHANDI/2026 (िनधा�रणवष� / Assessment Year: 2020-21) Shri Ram Bhaj ITO S/o Chota Ram, Furniture Shop Capt. Karan Singh Nagar बनाम/ Vs. Main Road, Khanauri Mandi, Sangrur Suman Road, Punjab – 148001 Punjab – 148027 �ायीलेखासं./जीआइआरसं./PAN/GIR No. BNUPB-7439-N (अपीलाथ�/Appellant) : (��थ� / Respondent) अपीलाथ�कीओरसे/ Appellant by : None (Adj. Application Rejected) ��थ�कीओरसे/Respondent by : Sh. Dr. Ranjit Kaur (Addl. CIT) - Ld. Sr. DR सुनवाईकीतारीख/Date of Hearing : 08-07-2026 घोषणाकीतारीख /Date of Pronouncement 09-07-2026 : आदेश / O R D E R 1. Aforesaid appeal by assessee for Assessment Year (AY) 2020- 21 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 25.02.2026 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 147 of the Act on 07.03.2025. 2. During hearing, it emerges that the first issue that fall for my consideration is taxability of interest on enhanced compensation as received by the assessee u/s 28 of Land Acquisition Act. The Ld. AO, considering various judicial decisions, brought to tax 50% of the
interest so received by the assessee u/s 56(2)(viii). The Ld. AO also made addition of cash deposit for Rs.9,90,900/-. The Ld. CIT(A) endorsed the view of Ld. AO for want of any representation from the assessee against which the assessee is in further appeal before Tribunal. 3. I find that the issue of interest on enhanced compensation has been adjudicated by coordinate bench of Chandigarh Tribunal in favor of the revenue in the case of Ajay Kumar & Others Vs. ITO (ITA No. 463/Chd/2023 and others dated 11.11.2025). Since the facts of the present case are identical to those considered by the Coordinate Bench in the aforesaid decision, I respectfully follow the same and hold that the Assessing Officer has rightly taxed 50% of the interest received by the assessee. Accordingly, I find no infirmity in the order of lower authorities to that extent. 4. So far as the addition of cash deposit is considered, keeping in mind the principles of natural justice, I deem it fit to grant another opportunity of hearing to the assessee. Accordingly, the impugned order is set aside to that extent and the addition of cash deposit stand restored back to the file of Ld. CIT(A) for de-novo adjudication with a direction to the assessee to plead and prove its case forthwith. 5. The appeal stands partly allowed for statistical purposes. Order pronounced on 09th July, 2026
-Sd- (MANOJ KUMAR AGGARWAL) ACCOUNTANT MEMBER
AS Dated: 09-07-2026 आदेश की �ितिलिप अ�ेिषत /Copy of the Order forwarded to : 1. अपीलाथ�/Appellant 2. ��थ�/Respondent 3. आयकरआयु�/CIT 4. िवभागीय�ितिनिध/DR 5. गाड�फाईल/GF
ASSISTANT REGISTRAR
ITAT CHANDIGARH
More judgments on Section 147
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