RANAJIT SURESH RAJAMANE,SOLAPUR vs. ITO, WARD 1, PANDHARPUR, PANDHARPUR

ITA 1678/PUN/2024Status: DisposedITAT Pune13 January 2026AY 2014-1510 pages
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What did the Tribunal hold?

The Tribunal held that the transfer of property is complete as per Section 2(47) of the Act even without registration of the sale deed, and therefore, the assessee is eligible for deduction under Section 54B if the conditions are otherwise met. The assessee had paid the consideration and obtained possession within the stipulated period.

What were the facts?

The assessee sold agricultural land and claimed exemption under Section 54B for investing the sale proceeds in another agricultural land. The Assessing Officer denied the exemption and made an addition under Section 69A as unexplained money because the sale deed for the new land was not registered within the prescribed time limit.

What were the issues?

Whether the non-registration of the sale deed for the new agricultural land within the prescribed time limit disentitles the assessee from claiming exemption under Section 54B, and if the sale consideration can be treated as unexplained money under Section 69A.

Which sections of the Income-tax Act were involved?

Section 69A,Section 54B,Section 2(47)

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Income Tax Appellate Tribunal, B BENCH,

Before: Dr. MANISH BORAD & MS. ASTHA CHANDRA

For Appellant: Smt. Deepa Khare
For Respondent: Shri Aviyogi Ambadkar
Hearing: 13.01.2026Pronounced: 27.01.2026

PER DR.MANISH BORAD, ACCOUNTANT MEMBER :

This appeal at the instance of the assessee is directed against the order of Ld. CIT(A) NFAC, Delhi dated 26.06.2024 framed u/s 250 of the Income Tax Act, 1961 for A.Y. 2014-15 which is arising out of order passed u/s 147 r.w.s 144 of the Act dated 21.12.2018. 2. Assessee has raised following grounds of appeal:- (i) The Id CIT(A) erred in law and on facts in confirming addition of Rs 1,14.25,000/- u/s 69A as unexplained money in respect of 50% of sale consideration on sale of property.

2 (ii)The Id CIT(A) erred in law and on facts in not appreciating that the sale consideration was received

The order continues below.

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