SAT PAUL BANSAL,CHANDIGARH vs. DCIT CIRCLE-1(1), CHANDIGARH, CHANDIGARH

ITA 1545/CHANDI/2025Status: DisposedITAT Chandigarh07 May 2026AY 2018-199 pages
AI SummaryAllowed

What were the facts?

The assessee claimed deduction under Section 54 for long-term capital gains on the sale of a property. The Assessing Officer denied the deduction, stating that the sale deed was executed in FY 2018-19, making the gains taxable in that year, and the investment in a new property was made prior to the specified period.

What did the Tribunal hold?

The Tribunal held that the transfer of property occurred on the date of the agreement to sell, as possession was handed over and full sale consideration was received by the assessee in AY 2018-19. The lien on the property, which caused the delay in the sale deed registration, was resolved before the sale deed was executed.

What were the issues?

Whether the date of transfer of property for capital gains purposes is the date of agreement to sell or the date of sale deed registration, and consequently, the eligibility for deduction under Section 54.

Which sections of the Income-tax Act were involved?

Section 54,Section 45(1),Section 2(47)(v),Section 53A,Section 2(47)(ii)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI RAJPAL YADAV & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Manoj Kumar Aggarwal (Accountant Member)

1.

Aforesaid appeal by assessee for Assessment Year (AY) 2018- 19arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 15-09-2025 in the matter of an assessment framed by Ld. AO u/s 143(3) of the Act on 27-09-2021. The sole issue that arises for our consideration is qua Long-Term Capital Gains on sale of property and assessee’s claim of deduction u/s 54. 2 AY : 2018-19

2.

The Ld.AR advanced grounds and referred to variou

The order continues below.

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