ANURADHA CHENNU,TIRUPATI vs. DCIT, CIRCLE-1(1), TIRUPATI
What were the facts?
The assessee did not file a return of income for AY 2013-14. Following a survey, it was found the assessee entered into a Joint Development Agreement (JDA) for land contribution, entitling them to 50 flats. The Assessing Officer (AO) treated the transfer of land as complete on JDA execution and computed long-term capital gains.
What did the Tribunal hold?
The Tribunal held that the assessee is eligible for deduction under Section 54F for all 50 flats receivable under the JDA, as the pre-amended provisions allowed for multiple residential units. The JDA itself constitutes documentary evidence for entitlement.
What were the issues?
Whether the assessee is eligible for deduction under Section 54F for multiple residential units received under a JDA prior to the Finance Act, 2014 amendment, and whether the faceless assessment proceedings were validly initiated.
Which sections of the Income-tax Act were involved?
Section 139,Section 148,Section 143(2),Section 2(47)(v),Section 53A,Section 147,Section 144B,Section 54F,Section 151A
AI-generated summary — verify with the full judgment below
Income Tax Appellate Tribunal, Hyderabad ‘ A ‘ Bench, Hyderabad
Before: Shri Vijay Pal Rao, Vice-Shri Madhusudan Sawdia
Per Madhusudan Sawdia, A.M.:
This appeal is filed by Smt. Anuradha Chennu (“the assessee”), feeling aggrieved by the order passed by the Learned Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi (“Ld. CIT(A)”) dated 22.09.2025 for the A.Y.2013-14. 2. The assessee has raised the following grounds of appeal:
The assessee has raised the following additional grounds of appeal:
“1. On the facts and in the circumstances of the case, the learned NFAC, Delhi erred in assuming juri iction under section 151A r.w.s 144B of
The order continues below.
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More judgments on Section 139
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- Mukesh Mishra, Thane vs ACIT, Circle 1, ThaneITA 5853/MUM/2026[2020-2021]Status: Disposed8 Oct 2026AY 2020-2021
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