RAMAVTAR,REWARI vs. ITO, REWARI, REWARI

ITA 140/DEL/2026Status: DisposedITAT Delhi10 February 2026AY 2020-21Bench: Sh. Satbeer Singh Godara (Judicial Member)9 pages
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What did the Tribunal hold?

The Tribunal held that the interest received under Section 28 of the Land Acquisition Act is an accretion to the value and part of enhanced compensation, aligning with the Supreme Court's decision in CIT vs. Ghanshyam HUF. Therefore, it is not taxable as income from other sources.

What were the facts?

The assessee received interest on land acquisition compensation. The lower authorities assessed this interest as income from other sources, invoking specific sections of the Income Tax Act. The assessee contended that this interest was part of enhanced compensation and exempt under Section 10(37).

What were the issues?

The key issue was whether interest on land acquisition compensation is taxable as income from other sources or is part of enhanced compensation exempt under Section 10(37). The Tribunal also considered the applicability of various Supreme Court and High Court decisions.

Which sections of the Income-tax Act were involved?

Section 28,Section 57(iv),Section 56(1)(a),Section 145A(b),Section 10(37),Section 45(5),Section 56(2)(viii)

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Income Tax Appellate Tribunal, DELHI BENCH ‘SMC’, NEW DELHI

Before: Sh. Satbeer Singh Godara

Hearing: 10.02.2026Pronounced: 10.02.2026

This assessee’s appeal for Assessment Year 2020-21 arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1083470019(1) dated 09.12.2025, in proceedings u/s 147 r.w.s. 144 of the Income Tax Act, 1961 (in short “the Act”).

2.

Heard both the parties at length. Case file perused.

3.

It emerges during the course of hearing that the sole substantive issue between the parties is that of correctness of the learned lower authorities’ action assessing the assessee’s interest component of land acquisition compensation u/s 28 of the Land Acquisition Act, 1894, while invoking section 57(iv) r.w.s. 56(1)(a) r.w.s. 145A(b) of the Act.

2 Ramavtar 4

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