ITO, WARD-3(3)(4),, AHMEDABAD vs. SMT. RAMILABEN G. PATEL,, AHMEDABAD

आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण, अहमदाबाद �यायपीठ आयकर अपीलीय अिधकरण आयकर अपीलीय अिधकरण अहमदाबाद �यायपीठ अहमदाबाद �यायपीठ ‘बी’ अहमदाबाद। अहमदाबाद �यायपीठ अहमदाबाद। अहमदाबाद। अहमदाबाद। IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, AHMEDABAD BEFORE SHRI P.M. JAGTAP, VICE-PRESIDENT AND SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER ITA No. 2968/Ahd/2017 Assessment Years : 2012-13 Ramilaben Ganpatbhai Patel, The Income-Tax Officer, 5, Rajsurya Bungalows, Vs Ward 3(3)(4), Nr. Fun Republic, Ramdevnagar, Ahmedabad Satellite, Ahmedabad-380051 PAN : AASPP 2683 G ITA No. 157/Ahd/2018 Assessment Years : 2012-13 The Income-Tax Officer, Ramilaben Ganpatbhai Patel, Ward 3(3)(4), Vs 5, Rajsurya Bungalows, Ahmedabad Nr. Fun Republic, Ramdevnagar, Satellite, Ahmedabad-380051 PAN : AASPP 2683 G अपीलाथ�/ (Appellant) �� यथ�/ (Respondent) Assessee by : Shri A.C. Shah, AR & Shri Bhadresh Gandhakwala, AR Revenue by : Shri R.R. Makwana, Sr. DR सुनवाई क� तार�ख/Date of Hearing : 26/04/2022 घोषणा क� तार�ख /Date of Pronouncement: 11/05/2022 आदेश / O R D E R PER P.M. JAGTAP, VICE-PRESIDENT :

These two appeals, one filed by the assessee being ITA No.2968/Ahd/2017 and other filed by the Revenue being ITA No.157/Ahd/2018, are cross appeals which are directed against the order of learned Commissioner of Income-Tax (Appeals)-7, Ahmedabad (“CIT(A)” in short) dated 23.10.2017 passed for Assessment Year 2012-13.

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consideration on 01.02.2013 declaring a total income of Rs.3,80,100/-. The said return was initially processed by the Assessing Officer under Section 143(1) of the Income-tax Act, 1961 (“the Act” in short). The assessment, however, was subsequently reopened by him on the basis of information received that the assessee had sold an immovable property along with other co-owners for a total consideration of Rs.5,11,50,000/- as per the sale deed dated 29.07.2011 (valuation for the purpose of stamp duty Rs.6,11,49,300/-) and the capital gain arising from the said sale was not offered to tax. A notice under Section 148 of the Act accordingly was issued by the Assessing Officer on 24.04.2014 after recording the reasons. Thereafter, a notice under Section 143(2) of the Act as well as 143(1) of the Act was issued by the Assessing Officer, in response to which written submission was filed by the assessee – a gist of which as given by the Assessing Officer in his order was as under:-

“1. The property was sold by Shri Ganpatbhai Kevaldas Patel vide agreement for sale in the month of December, 2000 for the consideration of Rs.53,26,000/- and paid amount of Rs.3,26,000/- on the date of banakhat and balance amount of Rs.50,00,000/- in cash on various date by the buyer Shri Ganpatbhai K. Patel. The property was sold to Hamadbhai Alibhai who is party of third part in the sale deed.

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Sr. No. Name of Party Amount (in Rs.) 1. Ganpatbhai Kevaldas Patel (Represented by 54,26,000 his four legal heirs) 2. Hamadbhai Alibhai 2,29,00,000 3. Cost of Premium paid to Govt. by the Buyer 2,28,24,000 Total 5,11,50,000

From the table given above it is clear that Shri Ganpatbhai Kevaldas Patel had received the sale Consideration of Rs.54,26,000/-. Further, the premium paid for the conversion of the land of Rs.2,28,24,000/- is to be deducted from the sale consideration. Further, the amount paid to Hamadbhai Alibhai of Rs.2,29,00,000/- should be taxed in the cash of Hamadbhai Alibhai.

“1. So far as premium paid to government of Rs.2,28,24,000/- for the conversion of land in to juni sharat is concern, it is stated that the said amount is required to deducted for the sale consideration. 2. In respect of sale consideration as per agreement for sale made on December, 2000 paid to Shri Ganpatbhai K. Patel, it is stated that the copy of agreement for sale has not been furnished during the course of assessment proceedings. However, the reference of the above agreement of sale in the sale deed, as per condition no.2.4. Further, the assessee has not furnished any evidence that the capital gain arising out of the sale of property as per agreement for sale has been shown by late Shri Ganpatbhai K. Patel in his return of income filed for the A.Y.2001-02. Hence, it can safely be concluded that the capital gain has not been charged in the A.Y.2001-02 at the time of transfer of property u/s.53A of transfer of property Act. Moreover, the payments were stated to have been made in cash to Shri Ganpatbhai K. Patel. However, no evidences have been furnished by the assessee. Therefore, the adjustment of Rs.53,26,000/- cannot be allowed from the sale consideration.

ITA Nos. 2968/Ahd/2017 & 157/Ahd/2018 Smt Ramilaben Ganpatbhai Patel-Cross Appeals AY : 2012-13 4 3. In respect of payment made to Hamadbhai Alibhai of Rs.2,29,00,000/- for surrendering his right in the land is not acceptable because the assessee has not furnished any documentary evidences regarding payment made to Hamadbhai Alibhai. In this connection, the assessee was specifically requested to produced Hamadbhai Alibhai vide show cause notice dated 10/03/2016 for verification of facts that the actual payment were made to Hamadbhai Alibhai as mentioned in the sale deed. In this connection the A.R. of the assessee as per order sheet entry dated 23/03/2016 has sought time up to 28/03/2016 for furnishing letters Hamadbhai Alibhai. However, he could not furnished the letters of Shri Hamadbhai Alibhai. Therefore, it is not proved that whether the sale consideration mentioned in the sale deed have actually been received by Hamadbhai Alibhai or the same have been actually deposited in his bank account. In absence of any evidences the payment made to Hamadbhai Alibhai has not been proved. It is worthwhile to mention here that in the ease of Smt.Arunaben Kaushikkumar Patel, the one of the co-owner, the Assessing Officer has sent the summons at the Ahmedabad and Sanand address but both summons were return for want of correct address. Further, Smt. Arunaben K Patel also failed to produce to Hamadbhai Alibhai. Similarly, the ample opportunities were accorded to the assessee also to produce to Hamadbhai Alibhai for the verification of the facts. However, the assessee filed to produce him before the undersigned. Therefore, it can safely be presumed that Hamadbhai Alibhai is dummy person and not real purchaser. This can be presumed because no evidences have been produced for the agreement of sale executed between Shri Ganpatbhai Patel and Hamadbhai Alibhai. The evidence for payment of cash of Rs.54,26,000/- as per agreement for sale have also not proved. Further, the payment of Rs.2,29,00,000/- paid as per sale deed also not been proved as per detailed discussion made (supra). In view of the above facts, it is held that Hamadbhai Alibhai is not real purchaser and hence, no deduction can be given from the purchase consideration in respect of payment made to Hamadbhai Alibhai.”

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remaining capital gain of Rs.2,24,61,868/- of other co-owners was assessed in the hands of the assessee on protective basis in the assessment completed under Section 143(3) of the Act read with Section 147 of the Act on 30.03.2016.

“5. Ground of appeal No. 2 is against the addition of Rs.2,24,61,868/- on account of long term capital gain on protective basis in the appellant's hands. It is seen from the assessment order that the profit in respect of consideration received by the appellant's brothers and sister, namely, Naginbhai Gapatbhaipatel, HUF, Narshibhai Gapatbhaipatel, HUF and Arunaben Gapatbhaipatel has been assessed in the hands of the appellant.

5.1 During the course of appellate proceedings, the appellant has made the following submissions:

"5. Addition of protective basis: 5.1 The learned AO has stated in last para of the assessment order as under: "Assessee has not furnished any such information in respect of other three, persons. In the circumstances, the remaining profit of other three persons (beneficiaries) viz. 1) Naginbhai Ganpatbhai Patel, 2) Narsihbhai Ganpatbhai Patel 3) Arunaben Ganpatbhai Patel of Rs.2,24,61,868/- is assessed in the hands of the assesses on protective basis. In the event of the assessment in respect of the above income hi the hands of correct beneficiaries, the protective addition as above shall he deleted.

5.2 From the above, it may please he seen that the share of other two legal heirs of Rs.2,24,61,868 is also added to the income of the assesses on protective basis since the assesses did not give any information about other two legal heirs. It may please he noted that the assessee is not aware about

ITA Nos. 2968/Ahd/2017 & 157/Ahd/2018 Smt Ramilaben Ganpatbhai Patel-Cross Appeals AY : 2012-13 6 other two legal heirs. The question of making addition of two legal heirs on protective basis does not arise. In any case, as stated above the addition is not required to be made at all since none of the legal heirs has received any consideration. They are only signing party on behalf of father Shri Gunpatbhai who passed away in 2010. Therefore, the entire addition both on substantive basis and on protective basis is not as per law and is not proper.

Your honour is prayed to delete the addition made and allow the appeal.”

5.2 I have carefully considered the assessment order, facts of the case and the submissions made by the appellant. It is seen from the same that the appellant is one of the four heirs of Ganpatbhai K. Patel, who died intestate and therefore in my view she can only be taxed in respect of her share in the property which is 25%, The appellant cannot he taxed for the shares of her brothers and sister. It is seen from the material available on record that the sister of the appellant i.e. Arunaben M. Patel has been charged with capital gain tax. However, the AO is directed to send the requisite information in respect of the appellant’s brothers to the concerned AO. The protective assessment of Rs.2,21,61,868/- made in the appellant’s case is deleted. This ground of appeal is partly allowed.”

The learned CIT(A), however, confirmed the action of the Assessing Officer in taxing the share of assessee in the Long Term Capital Gain in her hand on substantive basis, but directed the Assessing Officer to restrict the same to 1/4th of the total capital gain instead of 1/3rd after taking note of the fact that the assessee’s share in the property was actually 1/4th and not 1/3rd. The reasons given by the learned CIT(A) to arrive at this conclusion as contained in paragraph Nos. 4.2 to 4.2.6 of impugned order are reproduced below:-

“4.2 I have carefully considered the assessment order, facts of the case and the submissions made by the appellant. The facts of the case in brief are that Shri Ganpatbhai K. Patel was the original owner of agriculture land Navi Sharat at Moje: Sarkhej, who entered into a sale transaction through banakhat dated 15.07.2000 with one Shri Hamad Ali before his death on 19.10.2010. Shri Hamad Ali further agreed to sell the property to Gopal G. Sutaria/Gopesh G. Sutaria. The land was to be converted into juni sharat for which a premium of Rs.2,85,30,000/- was to be paid vide City Deputy Collector, Ahmedabad letter No. CDC/TNC/PREMIUM/S.R.38/2010 dated 01.03.2011. The

ITA Nos. 2968/Ahd/2017 & 157/Ahd/2018 Smt Ramilaben Ganpatbhai Patel-Cross Appeals AY : 2012-13 7 premium was been paid on behalf of the owner by the purchaser mentioned in sale deed dated 29.07.2011. The final registered sale deed was executed on 29.07.2011 ie in the A.Y.2012-13 wherein the legal heirs of Shri Ganpatbhai K. Patel put their signatures as per legal requirement. It is inferred from the documents on record that the effective seller is Shri Hamad Ali and the purchaser are S/Shri Gopal G.Sutariya / Gopesh G. Sutariya. The legal heirs of Ganpatbhai K. Patel as per 7/12 record of June, 2011 are as under:-

Naginbhai Ganpatbhai Patel Son Narsinhbhai Ganpatbhai Patel Son Ramilaben Ganpatbhai Patel Daughter-Appellant Arunaben Ganpatbhai Patel Daughter

4.2.2 The appellant has stated that the sale proceeds were received by her father during his life time and she had just signed sale deed on 29.07.2011 as a formality to fulfill the conditions of transaction dated 15.03.2000. However, as per information on record, the sale transaction has not been shown by Ganpatbhai K. Patel in A.Y.2001-02. It is also noted that there is no mention of terms & conditions of banakhat dated 15.07.2000 in the sale deed dated 29.07.2011, and hence it is concluded that the transaction was completed in A.Y. 2012-13, the year in which effective handing over of the impugned asset on sale took place.

4.2.3. The decision to tax sale proceeds of transaction in the hands of legal heirs in the A.Y.2012-13 is also arrived at from the fact that names of legal heirs including the appellant were incorporated in 7/12 land record in A.Y.2012-13 just before the final sale deed was executed on 29.07.2011. The land continued to be in the name of Ganpatbhai K. Patel (deceased) in the land records till A.Y.2012-13. Therefore, the appellant can’t avoid the tax liability on this transaction in A.Y.2012-13. Therefore, the AO's stand in this respect to tax the receipt in A.Y.2012-13 is hereby upheld.

4.2.4 Having decided that the proceeds are taxable in the hands of legal heirs, the question now arises as to what portion of the proceeds will be taxed in each. The signature portion of sale deed dated 29.07.2011 is reproduced as under:- “Declared today on 29 of the Month of July, 2011 in Ahmedabad. Sd/- (1) (Naginbhai Ganpatbhai Patel himself and as Manager i.e. the administrator of his joint Hindu family and in capacity on all behalf. Witness: - (1). Sd/- illegible (2).Sd/- illegible (2). Sd/- illegible

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(Narsinhbhai Ganpatbhai Patel, himself and as Manager i.e. the administrator of his joint Hindu family and in capacity on all behalf.

(3) Sd/- illegible (Ramilaben Ganpatbhai Kevaldas Patel)

(4) Sd/- illegible (Arunaben D/o. Ganpatbhai Kevaldas Patel)”

4.2.5 All the 4 legal heirs have signed as per legal requirements. As has also been mentioned in para 17 of the assessment order, the appellant is one of the four heirs of Ganpatbhai K. Patel who died intestate, therefore, her 25% of share of total consideration received can only be taxed. The appellant can't be taxed for anyone else's share of taxable income. Accordingly, she is to be taxed for 1/4th of the sale consideration.

4.2.6 I find that the case of the appellant's sister who is one of the co-owners of the property in question and is therefore based on identical facts has been decided by the ld.CIT(A), Ahmedabad vide his order No. CIT(A)-3/- Wd.3(3)(1)/152/15-16 dated 20.07.2016 wherein after a detailed discussion, it has been held that the four heirs of Ganpatbhai K. Patel, of which the appellant is one, have to be taxed in respect of the total sale consideration received at 1/4th of the same. The AO in his order has erroneously mentioned that the appellant's share would be 1/3rd. I also find that nowhere during the appellate proceedings has the appellant given any documentary evidence to establish the sale of land to Hamadbhai Alibhai or submit any documentary evidences to show that the entire sale consideration was actually received by him. No copies of bank statements have been furnished to establish the identity of these transactions. Therefore, I am of the considered opinion that the finding of the AO is correct. However, as discussed above, the appellant’s share would be 1/4th since she is the co-owner along with two brothers and one sister and not 1/3rd as noted by the AO. The AO is therefore directed to recompute the capital again accordingly. Ground of appeal No.1 is partly allowed.

Grounds raised in assessee’s appeal 1. The reassessment is bad in law inasmuch as there is no escapement of income.

ITA Nos. 2968/Ahd/2017 & 157/Ahd/2018 Smt Ramilaben Ganpatbhai Patel-Cross Appeals AY : 2012-13 9 2. The learned CIT(A) has erred in confirming the addition of Long Term Capital Gain (LTCG) of Rs.1,12,30,933/- on substantive basis inasmuch as the assessee has not received any consideration whatsoever and therefore the question of making addition even on substantive basis does not arise.

Grounds raised in Revenue’s appeal 1. The Ld. CIT(A) has erred in law and on facts in deleting the addition of Rs.2,24,61,868/- made on protective basis without appreciating the fact that assessment order have not yet been finalized in the case of co-owners in respect of their share of long term capital gain where the additions were made on substantive basis.

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impugned order, Capital Gain Tax in respect of her shares was duly charged in the hands of sister of the assessee namely Arunaben K. Patel. Similarly, the share of other two owners’ capital gain was chargeable to tax in their hands in their individual capacity and direction to this effect was given by the learned CIT(A) vide her impugned order to the Assessing Officer. Although the learned DR, in reply to a query raised by the Bench, has submitted that he has no information about any action being taken in the hands of other two co-owners namely Naginbhai G. Patel and Narsinhbhai G. Patel, we find merit in the contention of the learned Counsel for the assessee that there is no basis whatsoever to assess their share of capital gain in the hands of the assessee – even on protective basis. The learned DR has not been able to rebut or controvert this position. We, therefore, find no infirmity in the impugned order of the learned CIT(A) deleting the addition made by the Assessing Officer in the hands of the assessee on protective basis on account of share of other co-owners in the capital gain as the same was clearly chargeable to tax in their respective hands in individual capacity. The same is accordingly upheld dismissing the appeal of the Revenue.

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merely to complete the transaction. He has contended that the assessee thus did not receive any consideration on execution of sale deed dated 28.07.2011 and she therefore cannot be held liable for any tax on capital gain arising from the said sale. We are unable to accept this contention of the learned Counsel for the assessee. It is observed that no capital gain was offered by Shri Ganpatbhai K. Patel on the sale transaction claimed to be entered through banakhat in the year 2000. As noted by the learned CIT(A) in her impugned order, there was no mention relating to any terms and conditions of banakhat stated to be entered into on 15.07.2000 in the sale deed executed on 29.07.2011. There is also nothing on record to show that the property in question was transferred by Shri Ganpatbhai K. Patel to Shri Hamad Ali on 15.07.2000 within the definition of Section 2(47) of the Act. The said property is actually transferred within the meaning of Section 2(47) of the Act only on 29.07.2011 when the sale deed was executed and registered; and, as clearly mentioned in the sale deed, the transferors were the assessee and other three co-owners being the legal heir of Shri Ganpatbhai K. Patel. Shri Hamad Ali had joined the said sale deed only as confirming party and received certain amount out of total consideration as stated therein. As regards the contention of the learned Counsel for the assessee that no consideration was received by the assessee on sale of her share in the immovable property, it is observed that a sum of Rs.53,26,000/- was already received by Shri Ganpatbhai K. Patel in the past from Shri Hamad Ali and the said amount was adjusted against the sale consideration agreed between the parties as per sale deed dated 28.07.2011. As specifically mentioned in Clause 12 of the sale deed, the party of the second part i.e. assessee and other co-owners being sellers had agreed to give credit for the said amount as the amount paid up by the party of the first part i.e. purchaser on the execution of sale deed. In our opinion, it therefore cannot be said that there

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was no consideration received by the assessee and the other co-owners on transfer of property vide sale deed dated 28.07.2011.

“5.2 As it is decided that appellant in legally taxable for 1/4th of the sale proceeds, the question now to be decided as to what was the total sale proceeds received by the all heirs of Shri Ganpatbhai K. Patel (deceased).

The factual position about the total sale consideration as submitted by appellant is as under:-

Sr. No. Amount Particulars and name of the party receiving the consideration. 1 3,26,000 Received in cash by Father of party of Second Part, paid by party of the Third part at the time of Banakhat 2 50,00,000 Received in cash by Father of party of Second Part, paid by party of the Third part at the time of Banakhat 3 1,00,000 Received in cash at the time of Agreement by party of the Third part, paid by party of the First part 4 2,28,24,000 Paid by Ch. No.733482 of SBI dated 06.04.2011 as premium to State Government by part of First part 5 1,14,50,000 Paid by P.O. No.999356 of State Bank of India dated 28.07.2011 to party of Third part, by party of the First part 6 1,14,50,000 Paid by P.O. No.999358 of State Bank of India dated 28.07.2011 to party of Third part, by party of the First part Total 5,11,50,000

The legal heirs have received the sale proceeds at Sr. No.1 to 3 above totaling of Rs.54,26,000/- and at Sr. No.4 has gone to Govt. as premium for conversion of Navi Sharat to Purani Sharat. In fact this was also one of the conditions in original banakhat that asset has to be converted into Purani

ITA Nos. 2968/Ahd/2017 & 157/Ahd/2018 Smt Ramilaben Ganpatbhai Patel-Cross Appeals AY : 2012-13 13 Sherat before the final sale deed is executed. The amounts mentioned at Sr. No.5 & 6 have been received by 3rd party to sale agreement i.e. Shri Hamad Ali. Perusal of bank account does indicate that there is neither immediate cash withdrawal from the bank account of Hamad Ali nor there is any cash deposit in bank account of appellant. Therefore, the appellant is to be taxed for amounts other than mentioned at Sr. No.4 to 6 above.

5.3 Shri Pankaj K. Shah, AR vehemently argued that the LTCG should be taxed at Rs.13,56,500/- (Rs.54,26,000 / 4) as there is no evidence on record by the Department that any sale consideration over and above Rs.54,26,000/- has been received by the heirs in this case. As per para 15 of the assessment order, the issue was referred to DVO and based on the computation contained in para 16 of assessment order the LTCG is computed at Rs.5,76,16,800/-. If the total amount of Sr.No.4 to 6 above is deducted (Rs.4,57,24,000/- as per evidence on record) from the computation of LTCG based on DVO, then the four heirs have to be taxed at Rs.1,18,92,800/-. The difference of opinion between appellant and the AO is because of jantri value of Rs.6,00,49,300/- has been taken by the AO as total sale consideration as per specific provisions of section 50C of IT Act, 1961. I also don't find any objection filed by the appellant against jantri value during assessment proceedings. Hence recourse to the provisions of Sec.50C by the AO is found to be correct. As the appellant is one of the four heirs of Ganpatbhai K. Patel, it is decided that the appellant has earned taxable Long Term Capital Gain of Rs.29,73,200/- (1,18,92,800 / 4) and the same is confirmed. The appellant gets relief of Rs.5,46,43,600/-. The ground No.2/additional ground is partly allowed.”

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valuation adopted under Section 50C of the Act, break-up of consideration of the property as paid to Shri Hamad Ali as the confirming party etc.. We, therefore, modify the impugned order of the learned CIT(A) on this issue and direct the Assessing Officer to recompute the capital gain arising from the transfer of her share of property as assessable in the hands of the assessee as computed by the learned CIT(A) in the case of Smt. Arunaben K. Patel, other co-owner of the property.

Order pronounced in the open Court on 11th May, 2022 at Ahmedabad.

Sd/- Sd/-

(SIDDHARTHA NAUTIYAL) (P.M. JAGTAP) JUDICIAL MEMBER VICE-PRESIDENT Ahmedabad, Dated 11/05/2022 *Bt आदेश क� ��त�ल�प अ�े�षत/Copy of the Order forwarded to : 1. अपीलाथ� / The Appellant 2. ��यथ� / The Respondent. 3. संबं�धत आयकर आयु�त / Concerned CIT 4. आयकर आयु�त ( अपील ) / The CIT(A)- 5. �वभागीय ��त�न�ध आयकर अपील�य अ�धकरण/DR,ITAT, Ahmedabad, , 6. गाड� फाईल /Guard file. आदेशानुसार/ BY ORDER, TRUE COPY सहायक पंजीकार (Asstt. Registrar) आयकर अपील�य अ�धकरण ITAT, Ahmedabad 1. Date of dictation- …06.05.2022 … …. 2. Date on which the typed draft is placed before the Dictating Member ……09.05.2022…… Other member …09.05.2022…..…………. 3. Date on which the approved draft comes to the Sr.P.S./P.S. - …09.05.2022…………… 4. Date on which the fair order is placed before the Dictating Member for Pronouncement… 11.05.2022 5. Date on which the file goes to the Bench Clerk…11.05.2022…… 6. Date on which the file goes to the Head Clerk……………………………. 7. The date on which the file goes to the Assistant Registrar for signature on the order………………… 8. Date of Despatch of the Order………………