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Facts
The assessee appealed the CIT(A)'s order, which partly allowed relief against an assessment order dated 11.12.2019. The assessee's grievance pertains to the disallowance of transfer expenses and a partial allowance (50%) of exemption under section 54F for reinvestment.
Held
The Tribunal held that the claim for transfer expenses was not substantiated with evidence and upheld the disallowance. However, regarding the section 54F exemption, the Tribunal found that the property was purchased using the assessee's funds, and the son's name was included for convenience. Therefore, the assessee was held entitled to 100% exemption.
Key Issues
1. Whether transfer expenses related to the sale of immovable property are allowable without sufficient evidence. 2. Whether the assessee is entitled to full exemption under Section 54F when the reinvestment property is jointly owned with his son.
Sections Cited
143(3), 147, 271(1)(c), 271(1)(b), 80C, 54EC, 54F
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Income Tax Appellate Tribunal, JAIPUR BENCHES,”B-Bench” JAIPUR
Before: SHRIGAGAN GOYAL, AM& SHRI NARINDER KUMAR, JM
Result
In view of the above discussion, the appeal is partly allowed as regards 100 % exemption claimed by the assessee-appellant under section 54F of the Act. The Assessing Officer to make recalculations accordingly in accordance with law.
As regards the claim of transfer expenses, the appeal is hereby dismissed, while confirming the impugned order passed by Learned CIT(A). File be consigned to the record room after the needful is done by the office. Order pronounced in the open court on 11/11/2025.
Sd/- Sd/- ¼xxu xks;y½ ¼ujsUnz dqekj½ (GAGAN GOYAL) (NARINDER KUMAR) ys[kk lnL; @Accountant Member U;kf;d lnL;@Judicial Member Tk;iqj@Jaipur fnukad@Dated:- 11/11/2025 *Santosh आदेश की प्रतिलिपिअग्रेf’ात@ब्वचल वf जीम वतकमत वितूंतकमक जवरू The Appellant- Daulat Singh Haldea, Jaipur. 1. 2. izR;FkhZ@ The Respondent- ITO, Ward-3(3), Jaipur. 3. vk;djvk;qDr@ Theld CIT vk;djvk;qDr@CIT(A) 4.