ANKUL BANDOPANT MALLELWAR,NAGPUR vs. ITO WARD 5(3), NAGPUR

ITA 429/NAG/2026Status: DisposedITAT Nagpur31 August 2026AY 2020-215 pages
AI SummaryRemanded

What did the Tribunal hold?

The Tribunal condoned the delay in filing the appeal. It found that the assessee failed to furnish necessary evidence to support the claim for deduction under Section 54F. Therefore, the issue of verifying the deduction was restored to the Assessing Officer for fresh adjudication.

What were the facts?

The assessee's appeal concerns AY 2020-21, challenging reassessment proceedings initiated based on third-party information and the denial of deduction under Section 54F. The core dispute revolves around the correct year of taxability of capital gains from property sale and the fulfillment of conditions for the Section 54F exemption.

What were the issues?

The key issues are whether the reassessment proceedings were validly initiated and whether the assessee is entitled to a deduction under Section 54F for the investment in a new residential house, considering the timing of the property transfer and possession.

Which sections of the Income-tax Act were involved?

Section 147,Section 148,Section 250,Section 54F,Section 2(47)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, SMC BENCH,

Before: Dr. MANISH BORAD

For Appellant: Shri CS Mahaveer Parakh, CA (Virtual)
For Respondent: Shri Shiv Shankar Yadav, DR (Virtual)
Hearing: 04.08.2026Pronounced: 31.08.2026

This appeal at the instance of assessee pertaining to A.Y. 2020-21 is directed against the order passed by Ld. CIT(A), NFAC, Delhi u/s 250 of the Income-tax Act, 1961 dated 25.09.2025 which is arising out of the Assessment Order passed u/s. 147 r.w.s 144 of the IT Act dated 21.01.2025. 2. Assessee has raised following grounds of appeal:-

“1. That the Learned Assessing Officer erred in law and on facts in initiating reassessment proceedings under section 147/148 of the Act merely on the basis of third-party Insight information without independent application of mind, without verifying the corr

The order continues below.

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