Bikram Singh v. Land Acquisition\nCollector

10 SCC 243Reported decision1997#1887 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 366,005 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

Sh. Amrik Singh, Panchkula vs. ITO, Ward-2, Panchkula

ITA 219/CHANDI/2023[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Respondent: Shri Suraj Bhan Nain, Advocate

…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…

Sh. Pargat Singh, Panipat vs. ITO, Ward -1, Kaithal

ITA 180/CHANDI/2023[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Navdeep Monga, 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…

Sh. Gurinder Singh Grewal L/H of Parneet Kaur Grewal, Chandigarh vs. ACIT, Circle 4(1), Chandigarh

ITA 129/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18
For Respondent: Shri Suraj Bhan Nain, Advocate

…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…

M/S Yograj Chaudhary, Yamuna Nagar vs. ITO, Ward-5, Yamuna Nagar

ITA 116/CHANDI/2023[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

…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…

Sh. Ramesh Chand, Jagadhri vs. ITO, Ward-3, Yamuna Nagar

ITA 731/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
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…

Sh. Suresh Pal, Yamuna Nagar vs. ITO, Ward 5, Yamuna Nagar

ITA 668/CHANDI/2022[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…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…

Sh. Kulbir Singh S/O Sh. Jagir Singh, Pinjore vs. ITO, Ward 2, Panchkula

ITA 641/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…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…

Saroj Chaudhary Bala, Panchkula vs. ITO, Ward-4, Panchkula

ITA 635/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh11 Nov 2025AY 2017-18

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…

Smt. Shankri Devi, Panchkula vs. ACIT, Panckula Circle, Panchkula

ITA 596/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

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…

Harmala, Chandigarh vs. ITO, Ward 1(1), Nangal

ITA 432/CHANDI/2022[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…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…

Amrinder Singh Khubber, Ambala vs. ITO, W-5, Ambala

ITA 1044/CHANDI/2019[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

…payable 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…

Amrinder Singh Khubber, Ambala vs. ITO, W-5, Ambala

ITA 1043/CHANDI/2019[2012-13]Status: DisposedITAT Chandigarh11 Nov 2025AY 2012-13

…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…

Vijay Singh Chauhan, Noida vs. ITO, Ward-2(5), Noida

The appeal of the assessee is hereby dismissed

ITA 2561/DEL/2023[2015-16]Status: DisposedITAT Delhi26 Sept 2025AY 2015-16

Bench: Shri Sudhir Pareek & Shri Avdhesh Kumar Mishravijay Singh Chauhan, Income Tax Officer, House No.-193, Gali No.-3, Vs. Ward- 2(5), Noida, Village Chhalera, Sector-44, Uttar Pradesh, Noida, Uttar Pradesh India. India. Pan No: Aeipc4637E Appellant Respondent Assessee By : Sh. Naveen Kumar, Adv. Revenue By : Ms. Harpreet Kaur Hansra, Sr. Dr Date Of Hearing: 01.07.2025 Date Of Pronouncement: 26.09.2025 Order Per Sudhir Pareek, Jm: The Aforetitled Appeal Has Been Preferred Against The Order Of National Faceless Appeal Centre, Delhi [Hereinafter, In Short, ‘Cit(A)’] Dated 17.07.2023 For Ay 2015-16, By Which Appeal Of The Assessee Was Dismissed.

For Appellant: Sh. Naveen Kumar, AdvFor Respondent: Ms. Harpreet Kaur Hansra, Sr. DR
Section 10(37)Section 143(2)Section 28Section 34

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH: ‘F’: NEW DELHI BEFORE SHRI SUDHIR PAREEK, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER Vijay Singh Chauhan, Income Tax Officer, House No.-193, Gali No.-3, Vs. Ward- 2(5), Noida, Village Chhalera, Sector-44, Uttar Pradesh, Noida, Uttar Pradesh India. India. PAN No: AEIPC4637E APPELLANT RESPONDENT Assessee by : Sh. Naveen Kumar, Adv. Revenue by : Ms. Harpreet Kaur Hansra, Sr. DR Date of Hearing: 01.07.2025 Date of Pronouncement: 26.09.2025 ORDER PER SUDHIR PAREEK, JM: The aforetitled appeal has been preferred against the order of National Fa…

Veeraswamy Jotheeswaran, Tiruvallur vs. ITO, Ward-1, Tiruvallur

In the result, the appeal filed by the assessee is allowed

ITA 1756/CHNY/2025[2018-19]Status: HeardITAT Chennai12 Sept 2025AY 2018-19

Bench: Shri George George K

For Appellant: Shri N.V. Krishnan, AdvocateFor Respondent: Shri Y. Sudarshan, JCIT
Section 10(37)Section 142(1)Section 143(2)Section 143(3)Section 145Section 147Section 148Section 148ASection 250Section 56(2)(vii)

…(Punjab & Haryana); Mahender Pal Narang v. CBDT, Ministry of Finance [2021] 126 taxmann.com 105/279 Taxman 74/462 ITR 498 (SC); T.N.K. Govindaraju Chetty v. Commissioner of Income-tax [1967] 66 ITR 465 (SC); Bikram Singh v. Land Acquisition Collector [(1997) 10 SCC 243/[1996] 89 Taxman 119/224 ITR 551 (SC)]; Commissioner of Income-tax, Faridabad v. Ghanshyam (HUF) [(2009) 8 SCC 412/[2009] 182 Taxman 368/315 ITR 1 (SC)]; Commissioner of Income-tax. Faridabad v. Chet Ram (HUF) [(2018) 15 SCC 270/[2017] 86 taxmann.com 103/251 Taxman 4/400 ITR 23 (SC)]; Commissioner of Income Таx, Rajkot v. Govindbhai Mamaiya - [(20…

Devaraya Pillai Subramanian, Salem vs. ITO, Ward-1(1), Salem

In the result, appeal filed by the assessee is allowed

ITA 561/CHNY/2025[2017-18]Status: DisposedITAT Chennai04 Sept 2025AY 2017-18

Bench: Shri George George K & Shri S.R.Raghunathaआयकर अपील सं./Ita No.: 561/Chny/2025 धनिाजरण वर्ज / Assessment Year:2017-18 Devaraya Pillai Subramanian, Ito 58A, Sathyamoorthy Street, Vs. Ward – 1(1), Salem – 636 001. Salem. Tamil Nadu. [Pan: Aijps-3267-J] (अपीलाथी/Appellant) (प्रत्यथी/Respondent) अपीलाथीकीओरसे/Appellant By : Mr. N. Arjun Raj, Advocate प्रत्यथीकीओरसे/Respondent By : Ms. Sita Krishnamoorthy, Jcit

For Appellant: Mr. N. Arjun Raj, AdvocateFor Respondent: Ms. Sita Krishnamoorthy, JCIT
Section 56(2)(viii)

…(Punjab & Haryana); Mahender Pal Narang v. CBDT, Ministry of Finance [2021] 126 taxmann.com 105/279 Taxman 74/462 ITR 498 (SC); T.N.K. Govindaraju Chetty v. Commissioner of Income-tax [1967] 66 ITR 465 (SC); Bikram Singh v. Land Acquisition Collector [(1997) 10 SCC 243/[1996] 89 Taxтan 119/224 ITR 551 (SC)]; Commissioner of Income-tax, Faridabad v. Ghanshyam (HUF) [(2009) 8 SCC 412/[2009] 182 Taxman 368/315 ITR 1 (SC)]; Commissioner of Income-tax. Faridabad v. Chet Ram (HUF) [(2018) 15 SCC 270/[2017] 86 taxmann.com 103/251 Taxman 4/400 ITR 23 (SC)]; Commissioner of Income Таx, Rajkot v. Govindbhai Mamaiya - [(20…

Income Tax Officer, Panipat vs. Gurdev Singh, Panipat

In the result, the revenue’s appeal is allowed

ITA 5259/DEL/2024[2018]Status: DisposedITAT Delhi16 May 2025

Bench: Shri Shamim Yahya & Shri Sudhir Pareeka.Yr. : 2018-19 Ito, Ward-1, Room No. 203, Vs. Gurdev Singh, First Floor, Aayakar 1, Village Rajapur, Post Bhawan, Sector-6, Office Dadlana, Panipat Panipat-132024 (Pan: Fwxps8888E) (Appellant) (Respondent) Assessee By None Department By Shri Rajesh Kumar Dhanesta, Sr. Dr Date Of Hearing : 08.05.2025 Date Of Pronouncement : 16.05.2025

Section 145BSection 28Section 34Section 45(5)Section 56(2)(viii)

…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…

Jagjit Singh Kataria, Sonepat vs. Principal Commissioner of Income Tax, Rohtak

In the result, the Appeal of the Assessee is dismissed

ITA 1245/DEL/2024[2019-20]Status: DisposedITAT Delhi10 Dec 2024AY 2019-20

Bench: SHRI S RIFAUR RAHMN (Accountant Member), SHRI YOGESH KUMAR US (Judicial Member)

Section 10(37)Section 143(3)Section 144BSection 263Section 28Section 56(2)(viii)

…he State for keeping back the amount payable to the owner. ---" [Emphasis supplied] 17:00:34 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)…

Vachaspati Sharma, Gurgaon vs. ITO Ward -4(1), Gurgaon

In the result, the appeal of the assessee is dismissed

ITA 1180/DEL/2023[2019-20]Status: DisposedITAT Delhi21 Nov 2024AY 2019-20

Bench: Sh. S. Rifaur Rahman & Sh. Sudhir Kumarassessment Year: 2019-20 Vachaspati Sharma Vs Ito Village – Hayatpur Garhi Ward-4 Harsaru, Hayatpur, Gurgaon Gurgaon Pan No.Fnqps2021R (Appellant) (Respondent) Appellants By Sh. Suraj Bhan Nain, Advocate Sh. K.L. Pahwa, Advocate Respondent By Ms. Sapna Bhatia, Cit Dr Date Of Hearing: 11/09/2024 Date Of Pronouncement: 21/11/2024 Order Sh. Sudhir Kumar, Jm :

Section 10Section 10(37)Section 143Section 143(3)Section 18Section 234BSection 234DSection 28Section 45(5)Section 56

…f, cannot be a compensation or damages for the loss of the right to retain possession but only 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)…

Bhim Singh, Gurgaon vs. ITO Ward 1(3), Gurgaon

In the result, the appeal of the assessee in ITA No

ITA 255/DEL/2024[2019-20]Status: DisposedITAT Delhi02 Aug 2024AY 2019-20

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Vinod Arora, CAFor Respondent: Shri Amit Katoch, Sr. DR
Section 10Section 10(37)Section 28Section 34Section 56Section 56(2)(viii)Section 57Section 69ASection 80CSection 80D

…nly 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 S…

Veena Shah, Panipat vs. Pr CIT, Rohtak

The appeal stands dismissed

ITA 1222/DEL/2023[2018-19]Status: DisposedITAT Delhi28 Jun 2024AY 2018-19

Bench: SHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

Section 10(37)Section 143Section 143(3)Section 263Section 28Section 56(2)(viii)

…the Land Acquisition Act is not compensation received in lieu of compulsory acquisition of land under the Land Acquisition Act. The decision in Sham Lal Narula (supra) was subsequently followed by the Hon’ble Supreme Court in the case of Bikram Singh [(1997) 10 SCC 243], wherein, it was held that interest under Section 28 of the Land Acquisition Act 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 Na…