Jagannathan Sailaja Chitta, Chennai vs. ITO, Chennai
In the result, the appeal filed by the assessee is partly allowed for statistical purposes
ITA 1207/CHNY/2017[2012-13]Status: DisposedITAT Chennai27 Sept 2017AY 2012-13
Bench: Shri Sanjay Arora & Shri Duvvuru Rl Reddyआयकर अपील सं./I.T.A.No.1207/Mds/2017 "नधा"रण वष"/Assessment Year:2012-13 Smt. Jagannathan Sailaja Chitta, The Income Tax Officer, New No. 4, Old No. 33, Vs. International Taxation 2(2), Krishna Street, T. Nagar, Chennai 34. Chennai – 17. [Pan:Biqps3751R] (अपीलाथ" /Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से / Appellant By : Shri B. Ramakrishnan, C.A. ""यथ" क" ओर से/Respondent By : Shri A. Srinivasan, Jcit सुनवाई क" तार"ख/ Date Of Hearing : 13.07.2017 घोषणा क" तार"ख /Date Of Pronouncement : 27.09.2017 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Assessee Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 16, Chennai, Dated 27.03.2017 Relevant To The Assessment Year 2012-13, Wherein, Besides The Ld. Cit(A) Has Not Adjudicated The Additional Ground Raised By The Assessee With Regard To The Claim Of Exemption Under Section 54F Of The Income Tax Act, 1961 [“Act” In Short], The Ld. Cit(A) Has Erred In Confirming Various Disallowances Made Under Section 50C Of The Act, Confirming Disallowance
For Appellant: Shri B. Ramakrishnan, C.AFor Respondent: Shri A. Srinivasan, JCIT
Section 142(1)Section 143(2)Section 143(3)Section 234BSection 50CSection 50C(1)Section 54Section 54F
…er section 54F of the Act from the capital gain chargeable under section 45 of the Act, the full value on transfer of asset should also be the same as determined by the Stamp Value Authority and not less than that. As explained in CIT v. Citi Bank N.A. [2003] 261 ITR 570 (Bom), the different provisions of Chapter IV-E of the Act form part of one integrated code. The same are to be read harmoniously and not disjointedly. A deeming provision, it is trite law, is to be read in light of the object of the provision and, further, is to be taken to its logical end. When, for the purpose of computation under section 48 o…