SHARANJIT KAUR,CHANDIGARH vs. INCOME TAX OFFICER, WARD 2(1), CHANDIGARH

ITA 237/CHANDI/2025Status: DisposedITAT Chandigarh19 March 2026AY 2014-2015Bench: SHRI LALIET KUMAR (Judicial Member), SHRI MANOJ KUMAR AGGARWAL (Accountant Member)5 pages
AI SummaryPartly Allowed

What did the Tribunal hold?

The Tribunal held that the assessee had fully invested the net sales consideration of Rs.115.18 Lacs by 30-12-2014, fulfilling the investment requirement for Section 54F. It observed that delays in obtaining necessary permissions were beyond the assessee's control and that Section 54F should be construed liberally. Therefore, the Tribunal directed the AO to allow the deduction under Section 54F, while confirming an addition of Rs.84,940.

What were the facts?

The assessee sold an immoveable property for Rs.115.18 Lacs and claimed deduction under Section 54F for Rs.110.41 Lacs against the purchase of a residential villa. The Assessing Officer and CIT(A) denied the deduction, citing that the residential property was not completed within the prescribed time and the balance amount was not deposited in the Capital Gain Account Scheme.

What were the issues?

Whether the assessee is entitled to deduction under Section 54F for long-term capital gains on investment in a new residential property, considering the timelines for investment and property completion, and the requirement of depositing funds in the Capital Gains Account Scheme.

Which sections of the Income-tax Act were involved?

Section 54F,Section 147,Section 144B,Section 148,Section 139(5)

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, “B” BENCH, CHANDIGARH

Before: HON’BLE SHRI LALIET KUMAR, JM & HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM

Laliet Kumar (Judicial Member)

1.

Aforesaid appeal by assessee for Assessment Year (AY) 2014-15 arises out of an order of learned Commissioner of Income Tax (Appeals), NFAC [CIT(A)] dated 09-01-2025 in the matter of an assessment framed by Ld. Assessing Officer [AO] u/s 147 r.w.s. 144B of the Act on 23-03-2022. The prime grievance of the assessee is denial of deduction u/s 54F under the head Long-Term Capital Gains

(LTCG). Having heard rival submission

The order continues below.

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