RANJIT V SRIVATSAA,CHENNAI vs. ITO, NCW-3(2), CHENNAI

ITA 1755/CHNY/2025Status: DisposedITAT Chennai14 January 2026AY 2016-17Bench: SHRI MANU KUMAR GIRI (Judicial Member), SHRI S. R. RAGHUNATHA (Accountant Member)1 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the assessee had made the investment in construction of a new residential property before the expiry of the three-year period and was therefore eligible for the deduction under Section 54. The AO's action of taxing the capital gain in the impugned year was deemed erroneous.

What were the facts?

The assessee claimed a deduction under Section 54 for the sale of a long-term capital asset, having invested the sale proceeds in a residential property. The Assessing Officer (AO) denied the deduction, stating that the investment was not proven within the stipulated time. The CIT(A) upheld the AO's decision.

What were the issues?

Whether the assessee is eligible for deduction under Section 54 when the investment in a new residential property is made within the stipulated time, even if the assessment order was passed prior to the completion of the investment period.

Which sections of the Income-tax Act were involved?

Section 54,Section 143(3),Section 45

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, ‘B’ BENCH, CHENNAI

Before: SHRI MANU KUMAR GIRI & SHRI S. R. RAGHUNATHA

For Respondent: Ms. Gouthami Manivasagam, JCIT
Hearing: 25.11.2025Pronounced: 14.01.2026

PER S. R. RAGHUNATHA, AM:

This appeal by the assessee is filed against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi, for the assessment year 2016-17, vide order dated 28.04.2025. 2. The assessee has raised the following grounds of appeal: -

1.

The Learned CIT(A) erred in denying the claim of the appellant made U/s.54. :-2-: ITA. No

The order continues below.

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