Bikram Singh v. Land Acquisition\nCollector

10 SCC 243Reported decision1997#1904 most cited

What is Bikram Singh v. Land Acquisition\nCollector authority for?

Interest received under Section 28 of the Land Acquisition Act, 1894, from compensation for compulsory land acquisition is a revenue receipt and thus taxable under the Income Tax Act, 1961.

60

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2024 to 2026.

Also referred to as

Bikram Singh v Land Acquisition Collector · Section 28 Land Acquisition Act 1894 · taxability of interest · land acquisition compensation · revenue receipt · taxable interest income · Section 56(2)(viii) Income Tax Act · Section 45(5) Income Tax Act · enhanced compensation interest · Section 145A Income Tax Act · Sham Lal Narula

Sections most often in play

Section 1961Section 56(2)(viii)Section 10(37)Section 57(iv)Section 145ASection 45(5)Section 1894Section 143(2)

Issues it is cited on

section 2(viii)section 56(viii)section 155(16)section 45(5)(c)section 23(1a)section 45(5)(b)section 104section 145b(1)section 194lakeyman insurancesection 23(2)section 160

Judgments citing Bikram Singh v. Land Acquisition\nCollector

JAGPAL,GURUGRAM vs. PR. COMMISSIONER OF INCOME TAX, FARIDABAD

In the result, appeal of assessee in ITA No

ITA 2092/DEL/2024[2018-19]Status: DisposedITAT Delhi16 Jan 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri D.S. Sidhu, CIT-DR
Section 10(37)Section 145ASection 148Section 263Section 263(1)Section 28Section 34Section 56(2)(viii)

…t only compensation payable by the State for keeping back the amount payable to the owner.---" 17. The decision in Sham Lal Narula (supra) was subsequently followed by the Hon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition Collector [(1997) 10 SCC 243], wherein, it was held that interest under Section 28 of the Act of 1894 was in the nature of a revenue receipt and hence, the same was considered to be taxable. This position of law has been consistently reiterated by the Supreme Court in the case of T.N.K. Govindaraju Chetty v. CIT [(1967) 66 ITR 465 : AIR 1968 SC 129], Rama Bai v. CIT [1990 Sup…

BIR SINGH,FARIDABAD vs. INCOME TAX OFFICER, WARD 1(1), FARIDABAD

In the result, appeal of assessee in ITA No

ITA 3969/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 10(37)Section 28Section 34Section 56(2)(viii)

…only compensation payable by the State for keeping back the amount payable to the owner.-- -" 17. The decision in Sham Lal Narula (supra) was subsequently followed by the Hon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition Collector [(1997) 10 SCC 243], wherein, it was held that interest under Section 28 of the Act of 1894 was in the nature of a revenue receipt and hence, the same was considered to be taxable. This position of law has been consistently reiterated by the Supreme Court in the case of T.N.K. Govindaraju Chetty v. CIT [(1967) 66 ITR 465 : AIR 1968 SC 129], Rama Bai v. CIT [1990 Sup…

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

ITA 992/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh11 Nov 2025AY 2023-24

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…ayable by the State for keeping back the amount payable to the owner. ---" [Emphasis supplied] 27. The decision in Sham Lal Narula (supra) was subsequently followed by the Hon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition Collector [(1997) 10 SCC 243], wherein, it was held that interest under Section 28 of the Act of 1894 was in the nature of a revenue receipt and hence, the same was considered to be taxable. The relevant paragraphs of the said decision read as under:- "8. The controversy is no longer res integra. This question was considered elaborately by this Court in Sham Lal Narula (Dr) v…

LABH SINGH,PANCHKULA vs. INCOME TAX OFFICER, WARD NO 2,, PANCHKULA

ITA 725/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…by the State for keeping\nback the amount payable to the owner.\n___\"\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

BHUPINDER SINGH,AMBALA vs. INCOME TAX OFFICER, W-1, AMBALA, AMBALA

ITA 528/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15
For Respondent: \nShri Suraj Bhan Nain, Advocate

…e by the State for keeping\nback the amount payable to the owner.\n---\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

SH. HAKAM SINGH,PATIALA vs. INCOME TAX OFFICER, WARD-4, PATIALA

ITA 486/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

…e by the State for keeping\nback the amount payable to the owner.\n---\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

BALBIR SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, SIRSA, HARYANA

ITA 483/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…by the State for keeping\nback the amount payable to the owner.\n___\"\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

BISHAN CHAND,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5 (5), CHANDIGARH, CHANDIGARH

ITA 458/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…e by the State for keeping\nback the amount payable to the owner.\n___\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

SAT PAL,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5(5), , CHANDIGARH

ITA 243/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…ayable by the State for keeping\nback the amount payable to the owner.\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

NARENDER KAUR,KURUKSHETRA, HARYANA vs. INCOME TAX OFFICER WARD-1 , KURUKSHETRA

ITA 165/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…by the State for keeping\nback the amount payable to the owner.\n___\" [Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

BALVINDER SINGH,FATEHABAD vs. ITO WARD-1, FATEHABAD

ITA 153/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

…by the State for keeping\nback the amount payable to the owner.\n___\"\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

GURDEEP SINGH HUF,CHANDIGARH vs. ITO, WARD 5(5), CHANDIGARH

ITA 1153/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

…by the State for keeping\nback the amount payable to the owner.\n___\" [Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

JARNAIL SINGH,VILLAGE BHAGWANPUR, KALKA vs. ITO, WARD-2, PANCHKULA

ITA 1025/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…by the State for keeping\nback the amount payable to the owner.\n___\"\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

BALJEET KAUR,NADI MOHALLA AMBALA CITY vs. ITO WARD 1, AMBALA, AMBALA

ITA 92/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

…e by the State for keeping\nback the amount payable to the owner.\n___\"[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

ITA 876/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…ayable by the State for keeping back the amount payable to the owner. ---" [Emphasis supplied] 27. The decision in Sham Lal Narula (supra) was subsequently followed by the Hon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition Collector [(1997) 10 SCC 243], wherein, it was held that interest under Section 28 of the Act of 1894 was in the nature of a revenue receipt and hence, the same was considered to be taxable. The relevant paragraphs of the said decision read as under:- "8. The controversy is no longer res integra. This question was considered elaborately by this Court in Sham Lal Narula (Dr) v…

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21
For Respondent: \nShri Suraj Bhan Nain, Advocate

…e by the State for keeping\nback the amount payable to the owner.\n---\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

ANJU,MOHALI vs. INCOME TAX OFFICER WARD 6 (1) , MOHALI

ITA 563/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…by the State for keeping\nback the amount payable to the owner.\n___\"\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

ITA 531/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…ayable by the State for keeping back the amount payable to the owner. ---" [Emphasis supplied] 27. The decision in Sham Lal Narula (supra) was subsequently followed by the Hon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition Collector [(1997) 10 SCC 243], wherein, it was held that interest under Section 28 of the Act of 1894 was in the nature of a revenue receipt and hence, the same was considered to be taxable. The relevant paragraphs of the said decision read as under:- "8. The controversy is no longer res integra. This question was considered elaborately by this Court in Sham Lal Narula (Dr) v…

RAMKARAN ,PANCHKULA vs. NFAC, DELHI

Accordingly, finding no merit in the appeals, the same are hereby\ndismissed

ITA 503/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Respondent: \nShri Suraj Bhan Nain, Advocate

…by the State for keeping\nback the amount payable to the owner.\n___\"\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

SARVAN SINGH,AMBALA vs. INCOME TAX OFFICER-WARD 4, AMBALA

ITA 458/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…ayable by the State for keeping\nback the amount payable to the owner.\n[Emphasis supplied]\n27. The decision in Sham Lal Narula (supra) was subsequently followed by the\nHon'ble Supreme Court in the case of Bikram Singh v. Land Acquisition\nCollector [(1997) 10 SCC 243], wherein, it was held that interest under Section\n28 of the Act of 1894 was in the nature of a revenue receipt and hence, the\nsame was considered to be taxable. The relevant paragraphs of the said\ndecision read as under:-\n\"8. The controversy is no longer res integra. This question was considered\nelaborately by this Court in Sham Lal Narula…

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