BILESHIVALE MUDDANNA GOVARDHANA MURTHY,BENGALURU vs. DCIT, CENTRAL CIRCLE - 1(2), BENGALURU

ITA 2192/BANG/2025Status: DisposedITAT Bangalore05 March 2026AY 2013-14Bench: SHRI WASEEM AHMED (Accountant Member), SHRI KESHAV DUBEY (Judicial Member)1 pages
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What did the Tribunal hold?

The Tribunal held that the transaction concerning the immovable property did not constitute a transfer in the relevant year, as it was superseded by a partition decree. The disallowance of agricultural income was set aside due to lack of cogent reasons and the principle of consistency. The addition for A.Y. 2014-15, based solely on a statement without corroborative evidence, was also deleted.

What were the facts?

The assessee appealed against the order confirming the addition on the transaction of agreement to sale of immovable property and the disallowance of agricultural income. For the A.Y. 2014-15, the assessee also appealed against the confirmation of addition based on a third person's statement during a search.

What were the issues?

Whether long-term capital gains accrued in the assessment year due to an agreement to sell immovable property. Whether agricultural income of Rs. 7,75,000/- was rightly disallowed. Whether the addition of Rs. 94,85,250/- for A.Y. 2014-15, based on a third-party statement, is sustainable.

Which sections of the Income-tax Act were involved?

Section 2(47),Section 153A,Section 2(14),Section 4,Section 2(31),Section 132(4),Section 143(3)

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Income Tax Appellate Tribunal, ‘A’ BENCH, BANGALORE

Before: SHRI WASEEM AHMED & SHRI KESHAV DUBEY

For Appellant: Shri R.E Balasubramanyam, CA
For Respondent: Shri Azhar Zain VP, CIT(DR)
Hearing: 05.02.2026Pronounced: 05.03.2026

PER WASEEM AHMED, ACCOUNTANT MEMBER:

The set of 2 appeals filed at the instance of the assessee directed against the order under section 250 of the Income Tax Act, 1961, (hereafter the Act) dated 7th August 2025 for the assessment years 2013-14 to 2014-15. First, we take up assessee’s appeal in ITA No. 2192/Bang/2025 for A.Y. 2013-14. ITA No.2192 & 2193/Bang/2025 2. The Ground No. 1 of the assessee’s appeal is general in nature and does not require any separate and independent adjudication. Hence, the same is dismissed as infructuous.

3.

The issue raised by the assessee through Ground N

The order continues below.

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