CIT v. V.R. Karpagam

373 ITR 127High Court2015#3016 most cited

What is CIT v. V.R. Karpagam authority for?

The principles for exemption under Section 54 of the Income-tax Act apply equally to Section 54F, allowing exemption for multiple residential units received under a joint development agreement if the assessment year is prior to the Finance (No. 2) Act, 2014 amendment.

40

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2016 to 2025.

Also referred to as

CIT v. V.R. Karpagam · 373 ITR 127 · Section 54F · Section 54 · joint development agreement · residential units · exemption · Finance Act 2014 · amendment · assessment year

Sections most often in play

Section 54FSection 143(1)Section 143(3)Section 271(1)(c)Section 32Section 54

Issues it is cited on

section 54(1)section 13(2)joint development agreementsection 54findexed cost of acquisitionsection 54date of transferlong term capital gainslong term capital gainsection 13transferindia

Judgments citing CIT v. V.R. Karpagam

RAPHAEL JOHN (DECEASED),THRISSUR vs. ITO, WARD-2(3), THRISSUR

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

ITA 384/COCH/2024[2011-2012]Status: DisposedITAT Cochin06 Feb 2025AY 2011-2012

Bench: Shri Inturi Rama Rao

For Appellant: --- None---For Respondent: Smt.Leena Lal, Senior AR
Section 143(3)Section 54F

…e CIT(A) confirmed the action of the AO. In my considered opinion, the issue raised in this appeal is squarely covered by the judgment of the Hon’ble Madras High Court in the case 4 ITA No.384/Coch/2024. Raphael John (Deceased). of CIT v. V.R.Karpagam (2015) 373 ITR 127 (Mad.), wherein it was held vide para 4.3 as under:- “9. It is relevant to note herein that an amendment was made to the above said provision with regard to the word 'a' by the Finance Act (No.2) Act, 2014, which will come into effect from 1- 4-2015. the said amendment read as follows:— '32a. Words "constructed, one residential house in India" s…

DHIRAJKUMAR SOHANLAL THUKRAL ,MUMBAI vs. ACIT CIRCLE 17(1), MUMBAI

In the result, the appeal is partly allowed

ITA 3865/MUM/2024[2013-14]Status: DisposedITAT Mumbai12 Dec 2024AY 2013-14

Bench: Justice (Retd.) C.V. Bhadang & Shri B.R. Baskaran: A.Y : 2013-14 Dhirajkumar Sohanlal Thukral Vs. Asst. Commissioner Of Income 33/34, Garden View Apartment, Tax, Circle 17(1) Mumbai. Road No. 29, Sion (E), (Respondent) Mumbai 400 022. Pan : Aabpt5208Q (Appellant)

For Appellant: Ms. Kinjal BhutaFor Respondent: Shri R.R. Makwana, Sr. DR
Section 143(1)Section 271(1)(c)Section 32Section 54F

…house”. It is pointed out that the amendment cannot apply to the present case, which arises out of assessment year 2013-14. Reliance in this regard is placed on the decision of Madras High Court in Commissioner of Income Tax, Coimbatore vs Smt. V.R. Karpagam, 373 ITR 127 (Madras). It is submitted that this being a pure question of law, can be raised at any stage of the proceedings. It is, therefore, submitted that the appellant is entitled to 5 Dhirajkumar Sohanlal Thukral deduction under Section 54F of the Act in relation to all the three residential units. 12. The learned DR submitted that the appellant under…

BALASUNDARAM MAHALAKSHMI,COIMBATORE vs. DCIT, NON CORPORATE CIRCLE-4,, COIMBATORE

The appeal stand allowed in terms of our above order

ITA 1411/CHNY/2023[2013-14]Status: DisposedITAT Chennai03 Jul 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1411/Chny/2023 (िनधा9रणवष9 / Assessment Year: 2013-14) Ms. Balasundaram Mahalakshmi Dcit बनाम/ 216, Atd Road, Race Course, Non-Corporate Circle-4 Vs. Coimbatore-641 018. Coimbatore. "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aiopm-6371-Q (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ" कीओरसे/ Appellant By : Shri T. Banusekar (Advocate)- Ld.Ar " थ"कीओरसे/Respondent By : Shri Nilay Baran Som (Cit)-Ld. Dr सुनवाई की तारीख/Date Of Hearing : 20-06-2024 घोषणा की तारीख /Date Of Pronouncement : 03-07-2024 आदेश / O R D E R

For Appellant: Shri T. Banusekar (Advocate)- Ld.ARFor Respondent: Shri Nilay Baran Som (CIT)-Ld. DR
Section 143(3)Section 54F

…ace. This constructed area was contained in 36 residential flats. Out of these flats, impugned deduction u/s 54F was claimed in respect of 24 flats. The same was claimed as per the ratio of decision of Hon’ble High Court of Madras in the case of V.R.Karpagam (373 ITR 127). The details of these flats have been tabulated on Page No.6 of the assessment order. These flats were of different types and located on different floors. 3.3 The Ld. AO did not accept the claim of the assessee on the ground that the flats were spread over in different 15 types of blocks and each type of block was individual and isolated one. Si…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BANGALORE vs. SH. NARAYANAPPA RAMANNA, BANGALORE

In the result, appeal filed by the Revenue is dismissed

ITA 691/BANG/2023[2008-09]Status: DisposedITAT Bangalore16 Apr 2024AY 2008-09

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2008-09 Acit, Vs. Shri Narayanappa Ramanna, Circle – 4(1)(1), 1 B, Narayanapur Village, Bengaluru. K. R. Puram Hobli, Bengaluru – 560 016. Pan : Afmpr 3833 C Appellant Respondent Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bengaluru. Assessee By : Shri. Ganesh S, Advocate. Date Of Hearing : 16.04.2024 Date Of Pronouncement : 16.04.2024

For Appellant: Shri. Ganesh S, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bengaluru
Section 143(3)Section 250Section 54Section 54F

…tion of the revenue that the assessee is not entitled to benefit of exemption under section 54(1) of the Act in the facts of the case does not deserve acceptance." 9. The Hon’ble Madras High Court in the case of CIT Vs. Smt. V. R. Karpagam reported in [2015] 373 ITR 127 (Mad) had categorically held that the principles mentioned in section 54 of the Act is to be applied paripassu to section 54F of the Act. In view of the aforesaid judicial pronouncement, we hold that assessee is entitled to the benefit of section 54F of the Act in respect of all the units received by the assessee pursuant to the JDA, since the re…

FAROOQ ABDULLA MERCHANT,MUMBAI vs. ITO 23 (1)(4), MUMBAI

In the result, Ground No. V raised by the assessee is partly allowed

ITA 7906/MUM/2019[2014-15]Status: DisposedITAT Mumbai02 May 2023AY 2014-15

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Blefarooq Abdulla Merchant V. Income Tax Officer- Ward – 23(1)(4) Matru Mandir, Tardev Road A-1401, Poseidon Tower Mumbai – 400 007 Versova, Yari Road Above Indian Bank, Versova Andheri (W), Mumbai - 400061 Pan: Ahupm7426K (Appellant) (Respondent) Assessee Represented By : Shri Vimal Punamiya Department Represented By : Smt. Vranda U. Matkarni

Section 143(2)Section 54Section 54(1)

…eduction in respect of one flat. CIT(A) confirmed the order of AO. Held: AO was directed to allow the claim of the assessee with respect to two flats purchased by the assessee as it was pertinent to mention that in the case of CIT v. Smt. V R. Karpagam (2015) 373 ITR 127 (Mad), it was clearly held that the amendment to provision of section 54F is effective from 14-2015, which makes it clear that benefit of section 54F will be applicable to one residential house in India. Prior to the amendment, it was clear that a residential house would include multiple residential units. Thus, assessee was entitled to claim ded…

MANGILAL LAKAHJI CHOWDHARY,,PUNE vs. INCOME-TAX OFFICER, WARD - 3(1),, PUNE

Appeal is partly allowed in above terms

ITA 2791/PUN/2017[2013-14]Status: DisposedITAT Pune23 Sept 2022AY 2013-14

Bench: Shri S.S.Godara & Dr.Dipak P.Ripoteआयकरअपीलसं. / Ita No.2791/Pun/2017 िनधा"रण वष" / Assessment Year: 2013-14

Section 143(3)Section 2(47)Section 269USection 41(1)Section 53A

…T 252 CTR 336 Mad wherein exemption u/s 54F has been allowed even for more than one flat. Section 54F has been amended by Finance Act 2014 wherein word ”one’ house has been substituted for ‘a’ residential house. Madras High Court in case of CIT V V R Karpagam 373 ITR 127 has held that the amendment is prospective and will not apply to earlier assessment years.” 11.1 I have gone through the facts as well as the provision of Section 54F of the IT Act. The provision to Section 54F clearly states that the deduction shall not be available if an assessee owns more than one residential house on the date of transfer of…

ITO WARD - 30(1), NEW DELHI vs. KUSUM GUPTA, NEW DELHI

In the result appeal filed by the Revenue Department, stands allowed for statistical purposes

ITA 914/DEL/2020[2015-16]Status: DisposedITAT Delhi28 Jul 2022AY 2015-16

Bench: Shri N.K. Billaiya & Shri N.K. Choudhryassessment Year: 2015-16

For Appellant: Shri Vijay Jindal, Ld. CAFor Respondent: ShriAnujGarg, Ld. Sr. DR
Section 250Section 54

…9IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘C’ NEW DLEHI BEFORE SHRI N.K. BILLAIYA, ACCOUNTANT MEMBER AND SHRI N.K. CHOUDHRY, JUDICIAL MEMBER Assessment Year: 2015-16 Income-tax Officer, VersuS Kusum Gupta, E-40, GF, Masjid Ward 30(1), New Delhi. Moth, Greater Kailash, New Delhi. PAN: AFIPG0127R (Appellant) (Respondent) Appellant by : Shri Vijay Jindal, Ld. CA Respondent by : ShriAnujGarg, Ld. Sr. DR Date of hearing : 13.07.2022 Date of order : 28.07.2022 ORDER PER N.K. CHOUDHRY, J.M. This appeal has been preferred by the assessee against the order dated 04.12.2019, impugned herein, passed by the le…

MANOJ TEKRIWAL,MUMBAI vs. DCIT RG 24(2), MUMBAI

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 4147/MUM/2015[2010-11]Status: DisposedITAT Mumbai13 Jul 2022AY 2010-11

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri G.P. MehtaFor Respondent: Shri T. Shankar, Sr. AR CIT
Section 14ASection 234ASection 250Section 40Section 54

…Assessee apply on all fours to the facts of the present case.‖ 29. Similarly, in an earlier decision, while dealing with similar issue in respect of benefit claimed under section 54F of the Act, Hon’ble Madras High Court in CIT vs Smt. V.R. Karpagam, [2015] 373 ITR 127 (Madras), observed as under: Manoj Tekriwal ITA No.4147/Mum./2015 ―10. The above-said amendment to Section 54F of the Income Tax Act, which will come into effect only from 01.04.2015, makes it very clear that the benefit of Section 54F of the Income Tax Act will be applicable to constructed, one residential house in India and that clarifies the…

R.APPAJI (HUF), BY L/R. R. AMUDHA,PUDUCHERRY vs. ITO, PUDUCHERRY

The appeal stands partly allowed for statistical purposes in terms of our above order

ITA 2297/CHNY/2016[2011-12]Status: DisposedITAT Chennai21 Mar 2022AY 2011-12

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri T. Vasudevan (Advocate) – Ld. ARFor Respondent: Shri P. Sajit Kumar (JCIT) –Ld. DR
Section 143(3)Section 50CSection 54F

…ption on the entire amount of reinvestment was wholly unjustified and untenable in law. 8. The CIT(A) further failed to appreciate that the claim of assessee was in accordance with the provisions of law and the Madras High Court decision in V.R.Karpagam case (373 ITR 127) and hence the denial of exemption on a part of the property was arbitrary and without any statutory basis and hence the exemption u/s.54F is to be granted as claimed by the assessee. 9. The CIT(A) erred in confirming the disallowance of indexation on the improvement cost of Rs.128000 incurred by the assessee on land filling and fencing the prope…

ITO NON CORPORATE WARD 2(1), CHENNAI vs. A.M.K.SHAHUL HAMEED, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

ITA 1253/CHNY/2019[2012-13]Status: DisposedITAT Chennai24 Jan 2022AY 2012-13

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. No.1253/Chny/2019 िनधा"रण वष"/Assessment Years: 2012-13 The Income Tax Officer, Shri A.M.K. Shahul Hameed, Non Corporate Ward 2(1), Vs. Old No. 5, New No. 9, Rangan Street, Chennai 600 034. T. Nagar, Chennai 600 017. [Pan:Aabph6895F] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri Ar V. Sreenivasan, Addl. Cit ""थ" की ओर से/Respondent By : Shri B. Ramakrishnan, C.A. सुनवाई की तारीख/ Date Of Hearing : 03.01.2022 घोषणा की तारीख /Date Of Pronouncement : 24.01.2022 आदेश /O R D E R Per V. Durga Rao: The Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals)-2, Chennai Dated 11.01.2019 Relevant To The Assessment Year 2012-13. 2. Brief Facts Of The Case Are That The Assessee Filed His Return Of Income For The Assessment Year 2012-13 On 01.06.2013 Admitting Total Income Of ₹.10,82,700/-. The Case Was Selected For Scrutiny & After Following Due Process, The Assessment Was Completed Under Section 2

For Appellant: Shri AR V. Sreenivasan, Addl. CITFor Respondent: Shri B. Ramakrishnan, C.A
Section 2Section 54Section 54F

…The appellant succeeds on this ground. 8. On perusal of the case law relied on by the ld. CIT(A) in his appellate order, we find that the ld. CIT(A) has rightly followed the decision of the Hon’ble Jurisdictional High Court in the case of CIT v. V.R. Karpagam 373 ITR 127 (Mad), wherein, the Hon’ble Madras High Court has referred to the decision taken by the Hon’ble Karnataka High Court in the case of CIT v. Smt. K.G. Rukminiamma [2011] 331 ITR 211 (Kar.) to hold that the assessee is eligible for the deduction claimed under section 54F of the Act. The ld. DR could not controvert the above decisions of various High…

SUNANDAN KUMAR MINOCHA,DELHI vs. ITO, WARD-63(1), NEW DELHI

Accordingly, the appeal filed by the assessee is allowed

ITA 3135/DEL/2018[2013-14]Status: DisposedITAT Delhi23 Dec 2021AY 2013-14

Bench: Hon’Ble, Shri G.S. Pannu & Shri Amit Shukla

For Appellant: Shri Kapil Goel, AdvocateFor Respondent: Shri Harpal Singh, Senior DR
Section 127Section 143(3)Section 54

…eduction in respect of one flat. CIT(A) confirmed the order of AO. Held: AO was directed to allow the claim of the assessee with respect to two flats purchased by the assessee as it was pertinent to mention that in the case of CIT v. Smt. V R. Karpagam (2015) 373 ITR 127 (Mad), it was clearly held that the amendment to provision of section 54F is effective from 1- 4-2015, which makes it clear that benefit of section 54F will be applicable to one residential house in India. Prior to the amendment, it was clear that a residential house would include multiple residential units. Thus, assessee was entitled to claim d…

B.SUNDARARAJAN,CHENNAI vs. DCIT, NON CORPORATE CIRCLE, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and appeal of the assessee is allowed for statistical purposes

ITA 95/CHNY/2018[2008-09]Status: DisposedITAT Chennai16 Sept 2021AY 2008-09

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 431/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 The Assistant Commissioner Of Vs. Shri B. Sundararajan, Income Tax, No. 34, Umapathy Street, Non Corporate Circle 18(1), West Mambalam, Chennai 600 033. Chennai 600 034. [Pan:Aasps3969C] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 95/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 Shri B. Sundararajan, The Deputy Commissioner Of No. 34, Umapathy Street, Vs. Income Tax, West Mambalam, Chennai 600 033. Non Corporate Circle 18(1), Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Mrs. V.S. Sreelekha, Cit Assessee By Shri N. Arjunraj, Ca For : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 08.09.2021 घोषणा की तारीख /Date Of Pronouncement : 16.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Cross Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 31.10.2017 Relevant To The Assessment Year 2008-09. 2

For Respondent: Mrs. V.S. Sreelekha, CIT
Section 143(1)Section 143(3)Section 147Section 148Section 54F

…under section 143(3) r. w s. 147 of the Act by assessing the total income at ₹. 6,59,56,280/- after making the disallowance under section 54F of the Act of ₹. 6,39,34,520/-. On appeal, by following the decision in the case of CIT vs. Smt. V.R. Karpagam [2015] 373 ITR 127 (Mad.) and CIT vs. Gumanmal Jain [2017] 394 ITR 666 (Mad.), the Ld. CIT(A) directed the AO to allow assessee’s claim of deduction under section 54F of the Act. 3. The Revenue is in appeal before the Tribunal. The ld. DR submitted that even before the amendment to section 54F of the Act by the Finance Act, 2014, the section did not envisage the re…

ASSISTANT COMMISSIONER OF INCOME TAX NON CORPORATE CIRCLE 18(1), CHENNAI vs. SHRI. B SUNDARAJAN, CHENNAI

In the result, the appeal filed by the Revenue is dismissed and appeal of the assessee is allowed for statistical purposes

ITA 431/CHNY/2018[2008-09]Status: DisposedITAT Chennai16 Sept 2021AY 2008-09

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 431/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 The Assistant Commissioner Of Vs. Shri B. Sundararajan, Income Tax, No. 34, Umapathy Street, Non Corporate Circle 18(1), West Mambalam, Chennai 600 033. Chennai 600 034. [Pan:Aasps3969C] (अपीलाथ"/Appellant) (""थ"/Respondent) आयकर अपील सं./I.T.A. No. 95/Chny/2018 िनधा"रण वष"/Assessment Year:2008-09 Shri B. Sundararajan, The Deputy Commissioner Of No. 34, Umapathy Street, Vs. Income Tax, West Mambalam, Chennai 600 033. Non Corporate Circle 18(1), Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) Department By : Mrs. V.S. Sreelekha, Cit Assessee By Shri N. Arjunraj, Ca For : Shri S. Sridhar, Advocate सुनवाई की तारीख/ Date Of Hearing : 08.09.2021 घोषणा की तारीख /Date Of Pronouncement : 16.09.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: Both The Cross Appeals Filed By The Revenue As Well As Assessee Are Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 31.10.2017 Relevant To The Assessment Year 2008-09. 2

For Respondent: Mrs. V.S. Sreelekha, CIT
Section 143(1)Section 143(3)Section 147Section 148Section 54F

…under section 143(3) r. w s. 147 of the Act by assessing the total income at ₹. 6,59,56,280/- after making the disallowance under section 54F of the Act of ₹. 6,39,34,520/-. On appeal, by following the decision in the case of CIT vs. Smt. V.R. Karpagam [2015] 373 ITR 127 (Mad.) and CIT vs. Gumanmal Jain [2017] 394 ITR 666 (Mad.), the Ld. CIT(A) directed the AO to allow assessee’s claim of deduction under section 54F of the Act. 3. The Revenue is in appeal before the Tribunal. The ld. DR submitted that even before the amendment to section 54F of the Act by the Finance Act, 2014, the section did not envisage the re…

MADHU B KHATRI,MUMBAI vs. ITO WARD 32 (2)(2), MUMBAI

In the result, the assessee’s claim of deduction is allowed

ITA 6613/MUM/2019[2013-14]Status: DisposedITAT Mumbai01 Jul 2021AY 2013-14

Bench: Confirming The Sale Consideration Determined By Ld. Ao On Adopting The Market Value Of 2 Residential Flats, Ought To Have Considered The Understated Facts, Being;

Section 50CSection 50C(2)Section 54Section 541

…he new asset .....",accordingly the appellant is eligible to claim the deduction u/s 54 in respect of purchase of both residential house; 6 Madhu B.Khatri. In this respect, the appellant relies on under stated judicial decisions :- (i) CIT vs. V.R. Karpagam 373 ITR 127 (Mad-HC) "An amendment was made to section 54F with regard to the word V by the Finance ("No.2) Act, 2014. The said amendment to Section 54F of the Income Tax Act, which will come into effect only from 01.04.2015, makes it very clear that the benefit of Section 54F of the Income Tax Act will be applicable to constructed, one residential house in…

ITO NON CORP WARD 15 (3), CHENNAI vs. SMT. MAYURI ATUL SHAH, CHENNAI

In the result, the appeal filed by the Revenue is dismissed

ITA 453/CHNY/2018[2009-10]Status: DisposedITAT Chennai14 Jun 2021AY 2009-10

Bench: Shri Duvvuru Rl Reddy & Shri S. Jayaramanआयकर अपील सं./I.T.A. No. 453/Chny/2018 िनधा"रण वष"/Assessment Year:2009-10 The Income Tax Officer, Smt. Mayuri Atul Shah, Non Corporate Ward 15(3), Vs. Flat No. 802, Building F, Waterfront Chennai 34. Condominium, Behind Nittro Gym, Kalyaninagar, Pune 411 006. [Pan:Aacpa1988P] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri G. Johnson, Addl. Cit ""थ" की ओर से/Respondent By : Shri Vilesh Dalya, C.A. सुनवाई की तारीख/ Date Of Hearing : 20.04.2021 घोषणा की तारीख /Date Of Pronouncement : 14.06.2021 आदेश /O R D E R Per Duvvuru Rl Reddy: This Appeal Filed By The Revenue Is Directed Against The Order Of The Ld. Commissioner Of Income Tax (Appeals) 15, Chennai, Dated 29.11.2017 Relevant To The Assessment Year 2009-10 In Directing The Assessing Officer To Allow The Deduction Under Section 54 Of The Income Tax Act, 1961 [“Act” In Short].

For Appellant: Shri G. Johnson, Addl. CITFor Respondent: Shri Vilesh Dalya, C.A
Section 143(3)Section 148Section 50CSection 54

…of exemption under section 54 of the Act of ₹.9,11,300/- was brought to tax. On appeal, by following the decision in the case of CIT v. D. Ananda Basappa (2009) 180 Taxman 4/309 ITR 329 (Kar.) as well as the decision in the case of CIT v. V.R. Karpagam (2015) 373 ITR 127 (Mad), the ld. CIT(A) allowed both the grounds raised under section 54 of the Act and directed the Assessing Officer to allow the deduction claimed under section 54 of the Act for investment of long term capital gain in both the flats. 3 I.T.A. No. 453/Chny/18 3. Aggrieved, the Revenue is in appeal before the Tribunal. The ld. DR has submitted…

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5584/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…T versus Ericsson AB 343 ITR 470 (Delhi), DIT versus Nokia networks OY 358 ITR 259 (Delhi), DIT versus LG Cable Ltd ITA 703 of 2009 dated 24/12/2010 (Delhi), DIT versus Xelo Pty Ltd 203 taxman 475 (Bombay), LS cable Ltd 331 ITR 35 (AR), Deepak Cable India Ltd 337 ITR 127, ION Geophysical Corporation versus DCIT 72 taxmann.com 298 and National petroleum construction Co versus ACIT 20 ITR (T) 545 (Delhi). He further submitted that the provisions of Section 44 BB of the income tax are applicable only to the services/facilities and providing plant and machinery on hire and does not apply on sale of goods and material…

MI OVERSEAS LTD.,MUMBAI vs. ADIT, DEHRADUN

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5583/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…T versus Ericsson AB 343 ITR 470 (Delhi), DIT versus Nokia networks OY 358 ITR 259 (Delhi), DIT versus LG Cable Ltd ITA 703 of 2009 dated 24/12/2010 (Delhi), DIT versus Xelo Pty Ltd 203 taxman 475 (Bombay), LS cable Ltd 331 ITR 35 (AR), Deepak Cable India Ltd 337 ITR 127, ION Geophysical Corporation versus DCIT 72 taxmann.com 298 and National petroleum construction Co versus ACIT 20 ITR (T) 545 (Delhi). He further submitted that the provisions of Section 44 BB of the income tax are applicable only to the services/facilities and providing plant and machinery on hire and does not apply on sale of goods and material…

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5565/DEL/2013[2010-11]Status: DisposedITAT Dehradun08 Jun 2021AY 2010-11

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…T versus Ericsson AB 343 ITR 470 (Delhi), DIT versus Nokia networks OY 358 ITR 259 (Delhi), DIT versus LG Cable Ltd ITA 703 of 2009 dated 24/12/2010 (Delhi), DIT versus Xelo Pty Ltd 203 taxman 475 (Bombay), LS cable Ltd 331 ITR 35 (AR), Deepak Cable India Ltd 337 ITR 127, ION Geophysical Corporation versus DCIT 72 taxmann.com 298 and National petroleum construction Co versus ACIT 20 ITR (T) 545 (Delhi). He further submitted that the provisions of Section 44 BB of the income tax are applicable only to the services/facilities and providing plant and machinery on hire and does not apply on sale of goods and material…

ADIT (INTERNATIONAL TAXATION), DEHRADUN vs. M/S. M.I, OVERSEAS LTD., MUMBAI

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 5564/DEL/2013[2007-08]Status: DisposedITAT Dehradun08 Jun 2021AY 2007-08

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…T versus Ericsson AB 343 ITR 470 (Delhi), DIT versus Nokia networks OY 358 ITR 259 (Delhi), DIT versus LG Cable Ltd ITA 703 of 2009 dated 24/12/2010 (Delhi), DIT versus Xelo Pty Ltd 203 taxman 475 (Bombay), LS cable Ltd 331 ITR 35 (AR), Deepak Cable India Ltd 337 ITR 127, ION Geophysical Corporation versus DCIT 72 taxmann.com 298 and National petroleum construction Co versus ACIT 20 ITR (T) 545 (Delhi). He further submitted that the provisions of Section 44 BB of the income tax are applicable only to the services/facilities and providing plant and machinery on hire and does not apply on sale of goods and material…

ADIT, DEHRADUN vs. M/S. M.I. OVERSEAS LTD., NOIDA

In the result ITA number 5584/Del/2013 filed by the assessee for assessment year

ITA 3045/DEL/2013[2006-07]Status: DisposedITAT Dehradun08 Jun 2021AY 2006-07

Bench: Shri Sudhanshu Srivastava & Shri Prashant Maharishi

For Appellant: Shri Ajay Vohra, Sr. AdvFor Respondent: Shri Thakur Singh Mapwal, JCIT DR
Section 263Section 44BSection 9

…T versus Ericsson AB 343 ITR 470 (Delhi), DIT versus Nokia networks OY 358 ITR 259 (Delhi), DIT versus LG Cable Ltd ITA 703 of 2009 dated 24/12/2010 (Delhi), DIT versus Xelo Pty Ltd 203 taxman 475 (Bombay), LS cable Ltd 331 ITR 35 (AR), Deepak Cable India Ltd 337 ITR 127, ION Geophysical Corporation versus DCIT 72 taxmann.com 298 and National petroleum construction Co versus ACIT 20 ITR (T) 545 (Delhi). He further submitted that the provisions of Section 44 BB of the income tax are applicable only to the services/facilities and providing plant and machinery on hire and does not apply on sale of goods and material…

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