INCOME TAX OFFICER, KARNAL vs. PREM CHAND MADAN, KARNAL

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ITA 8559/DEL/2025Status: DisposedITAT Delhi13 May 20263 pages

In favour of the assessee: the Revenue's appeal was dismissed. From the AI summary of this appeal.

AI SummaryDismissed

What did the Tribunal hold?

The Tribunal dismissed the Revenue's appeals. This was primarily based on the tax effect of the appeals being below the monetary limit prescribed by CBDT Circular No. 9/2024.

What were the facts?

The Revenue filed appeals against the CIT(A)'s order allowing exemption for interest on enhanced compensation. The assessee had not initially claimed this exemption in their ITR.

What were the issues?

Whether the CIT(A) was justified in allowing exemption for interest on enhanced compensation when not claimed by the assessee, and whether amended sections of the Act and High Court judgments were correctly applied.

Which sections of the Income-tax Act were involved?

Section 56(2)(viii),Section 57(iv),Section 145A,Section 145B

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, DELHI ‘G’ BENCH,

Before: SHRI SATBEER SINGH GODARA, & SHRI NAVEEN CHANDRA

For Appellant: Shri Rajeev Sachdeva, C.A
For Respondent: Shri Choudhary N.C. Roy, Sr. D.R
Hearing: 13.05.2026Pronounced: 13.05.2026

Heard together (2 matters)

ITA No.8559/DEL/2025
ITA No.8560/DEL/2025

Read from the judgment's own cause title. This page is filed under one of them.

PER NAVEEN CHANDRA, ACCOUNTANT MEMBER:-

These two appeals by the Revenue are preferred against the order of the Commissioner of Income Tax (Appeals) – Addl/JCIT(2)-2, Coimbatore dated 07.10.2025 arising out of the rectification order dated 24.06.2022 passed by ITO, Ward-1, Karnal (Haryana) Delhi under section

ITA Nos. 8559 & 8560/Del/2025 [A.Ys. 2016-17 & 2018-19] ITO vs. Prem Chand Madan 154 of the Income Tax Act, 1961 (hereinafter referred as “the Act”) and pertaining to Assessment Years 2016-17 & 2018-19, respectively. 2. Since the above captioned appeals were heard together and the grounds and facts in issues are identical, both the appeals are being disposed of by this common order for the sake of convenience and brevity. 3. The grounds of appeal of the assessee are as under : 1. “Whether on the facts and in the circumstances of the case, the Ld. Addl. CIT(A) was right in law in allowing the claim of exemption for the interest received on enhanced compensation received under the Land Acquisition Act whereas the assessee had not claimed the said exemption in his ITR." 2. Whether the Ld. Addl. CIT(A) is right in law in allowing the appeal of the assessee in view of the amended provisions of sections 56(2)(viii), 57(iv), 145A and 145B of the Act ? 3. Whether the Ld. Addl. CIT(A) is right in not following the judgement of Hon'ble Punjab and Haryana High Court in the case of Mahender Pal Narang Vs. CBDT, [2020] 423ITR 13(P&H), which has attained finality after dismissal of SLP by the Hon'ble Apex Court?”

4.

We have heard the rival submissions and have perused the relevant material on record. At the very outset, we find that the tax effect for both the AY 2016-17 and AY 2018-19 are Rs 6,14,644/- and Rs 10,18,512/- respectively. The tax effect for both the AYs are therefore below the prescribed limit as prescribed in the CBDT Circular No. 9/2024 dated 17.09.2024. Further we are not appraised of any facts that these appeals

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ITA Nos. 8559 & 8560/Del/2025 [A.Ys. 2016-17 & 2018-19] ITO vs. Prem Chand Madan fall under any exception clause of the said Circular. These appeals are accordingly, dismissed with liberty to the revenue to approach the Tribunal as per the provisions of law, should it feel that the tax effect is more than Rs. 60 lakhs. 5. In the result, both the appeals of the Revenue in ITA Nos. 8559 & 8560/DEL/2025 are dismissed. The order is pronounced in the open court on 13.05.2026.

Sd/- Sd/- [SATBEER SINGH GODARA] [NAVEEN CHANDRA] JUDICIAL MEMBER ACCOUNTANT MEMBER Dated: 19th May, 2026. Priti Yadav, Sr.PS* Copy forwarded to: 1. Assessee 2. Respondent 3. CIT 4. CIT(A) 5. DR Asst. Registrar, ITAT, New Delhi

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