Mahender Pal Narang v. CBDT

161 Taxmann.com 301High Court2024#543 most cited

What is Mahender Pal Narang v. CBDT authority for?

Interest received as enhanced compensation under Section 28 of the Land Acquisition Act, 1894, for compulsory acquisition of land is taxable as "income from other sources" under Sections 56(2)(viii) and 57(iv) of the Income-tax Act, 1961, and is not exempt under Section 10(37).

178

judgments rely on this decision, according to BharatTax’s citation analysis of 367,368 Indian tax judgments — from 2021 to 2026.

Also referred to as

Mahender Pal Narang v. CBDT · interest enhanced compensation · compulsory land acquisition · Section 28 Land Acquisition Act · Section 56(2)(viii) Income Tax Act · Section 57(iv) Income Tax Act · income from other sources · Section 10(37) · taxability of interest · Section 145B

Issues it is cited on

Judgments citing Mahender Pal Narang v. CBDT

Ashok Kumar Thakral, Jagadhri vs. Principal Commissioner of Income Tax, Panchkula

In the result, all the above appeals filed by the respective assessee’s are dismissed

ITA 455/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Feb 2026AY 2015-16

Bench: the Tribunal as pointed out by the Registry. Considering that the issue involved is purely legal in nature, and respectfully following the ratio laid down by the Hon'ble Supreme Court in Collector, Land Acquisition v. Mst. Katiji & Others [(1987) 167 ITR 471 (SC)], which emphasizes that substantial justice should prevail over technical considerations, we condone the delay in filing these appeals.3. We shall take appeal of the assessee in ITA No. 167/Chd/2023 for A.Y 2018-19 as a lead case f

For Appellant: Shri Parikshit Aggarwal, C.A (Virtual)For Respondent: Shri Manav Bansal, CIT, DR

…/s 263:  Then revision proceedings u/s 263 were initiated by issuing SCN on 02.02.2023 alleging that the interest on enhanced compensation claimed as exempt is taxable u/s 56(2)(viii) and for this, the Ld. PCIT placed reliance on Mahender Pal Narang vs CBDT (423 ITR 13) (P&H HC), wherein it was held that “13…interest received on compensation or enhanced compensation is to be treated as "income from other sources" and not under the head "capital gains" & Puneet Singh vs CIT, Karnal (2019) (415 ITR 215) (P&H HC) wherein it was held that “16. The Tribunal relying upon the decision of this Court in Manjeet Singh (HU…

Satender Kumar, Sarita Vihar vs. Income Tax Officer, Civic Centre

In the result, appeal of the assessee is allowed

ITA 229/DEL/2026[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 229/Del/2026 : Asstt. Year: 2020-21 Satender Kumar, Vs Income Tax Officer, 56, Ali Village, Sarita Vihar, Ward-28(1), New Delhi-110076 New Delhi-110001 (Appellant) (Respondent) Pan No. Afxpk4995C Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1082434098(1) Dated 10.11.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 229/Del/2026 : Asstt. Year: 2020-21 Satender Kumar, Vs Income Tax Officer, 56, Ali Village, Sarita Vihar, Ward-28(1), New Delhi-110076 New Delhi-110001 (APPELLANT) (RESPONDENT) PAN No. AFXPK4995C Assessee by: None Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 10.02.2026 Date of Pronouncement: 10.02.2026 ORDER This assessee’s appeal for Assessment Year 2020-21 arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S/250/2025-26/1082434098(1) dated 10.11.2025, in proceeding…

Braham Dutt Vashist, Gurgaon vs. ITO-Ward -1(3), Gurgaon

In the result, appeal of the assessee is allowed

ITA 170/DEL/2026[2014-15]Status: DisposedITAT Delhi10 Feb 2026AY 2014-15

Bench: Sh. Satbeer Singh Godaraita No. 170/Del/2026 : Asstt. Year: 2014-15 Braham Dutt Vashist, Vs Income Tax Officer, C/O Ca M. R. Sahu, Ward-1(3), H. No. 651, 1St Floor, Sector-10A, Gurgaon-122001 Near G. D. Goenka Public School, Gurgaon-122001 (Appellant) (Respondent) Pan No. Affpv0127D Assessee By: Sh. M. R. Sahu, Ca Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2014-15 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1083989454(1) Dated 23.12.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. M. R. Sahu, CAFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 170/Del/2026 : Asstt. Year: 2014-15 Braham Dutt Vashist, Vs Income Tax Officer, C/o CA M. R. Sahu, Ward-1(3), H. No. 651, 1st Floor, Sector-10A, Gurgaon-122001 Near G. D. Goenka Public School, Gurgaon-122001 (APPELLANT) (RESPONDENT) PAN No. AFFPV0127D Assessee by: Sh. M. R. Sahu, CA Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 10.02.2026 Date of Pronouncement: 10.02.2026 ORDER This assessee’s appeal for Assessment Year 2014-15 arises against the CIT(A)/NFAC, Delhi’s DIN & order No.…

Ramavtar, Rewari vs. ITO, Rewari

In the result, appeal of the assessee is allowed

ITA 140/DEL/2026[2020-21]Status: DisposedITAT Delhi10 Feb 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 140/Del/2026 : Asstt. Year: 2020-21 Ramavtar, Vs Income Tax Officer, C/O Anu Jain & Company, Ward-1(3), 272-R, First Floor, Near Palika Near Hindu High School, Complex, Model Town, Rewari, Model Town, Rewari, Haryana-123401 Haryana-123401 (Appellant) (Respondent) Pan No. Apdpa0001R Assessee By: None Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 10.02.2026 Date Of Pronouncement: 10.02.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1083470019(1) Dated 09.12.2025, In Proceedings U/S 147 R.W.S. 144 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: NoneFor Respondent: Sh. Manoj Kumar, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 140/Del/2026 : Asstt. Year: 2020-21 Ramavtar, Vs Income Tax Officer, C/o Anu Jain & Company, Ward-1(3), 272-R, First Floor, Near Palika Near Hindu High School, Complex, Model Town, Rewari, Model Town, Rewari, Haryana-123401 Haryana-123401 (APPELLANT) (RESPONDENT) PAN No. APDPA0001R Assessee by: None Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 10.02.2026 Date of Pronouncement: 10.02.2026 ORDER This assessee’s appeal for Assessment Year 2020-21 arises against the CIT(A)/NFAC, Delhi’…

Mahender Malik, Hisar vs. ITO, Ward -(1), Hisar

In the result, appeal of the assessee is allowed

ITA 5586/DEL/2024[2018-19]Status: DisposedITAT Delhi29 Jan 2026AY 2018-19

Bench: Shri Satbeer Singh Godara & Shri Manish Agarwalassessment Year: 2018-19 Sh. Mahender Malik, Vs. Income Tax Officer, 388, Satroad Khurad, Near Ward-1, Adarsh High School, Hisar Hisar Pan: Bitpm5341N (Appellant) (Respondent) Assessee By Ms. Karishma Rathore, Adv. Sh. Mayank Patawari, Adv. Department By Sh. Yogeshwar Sharma, Sr. Dr Date Of Hearing 29.01.2026 Date Of Pronouncement 29.01.2026 Order Per Satbeer Singh Godara, Jm This Assessee’S Appeal For Assessment Year 2018-19, Arises Against The Commissioner Of Income Tax (Appeals)/National Faceless Appeal Centre [In Short, The “Cit(A)/Nfac”], Delhi’S Din & Order No. Itba/Nfac/S/250/2024-25/1069269047(1), Dated 30.09.2024 Involving Proceedings Under Section 154 Of The Income- Tax Act, 1961 (Hereinafter Referred To As ‘The Act’). Heard Both The Parties. Case File Perused. 2. For The Reasons Stated In The Assessee’S Condonation Averments, Delay Of 3 Days In Filing Of The Instant Appeal Is Condoned In Light Of Collector, Land & Acquisition Vs. Mst. Katiji & Others (1987) 167 Itr 471 (Sc). 3. It Emerges During The Course Of Hearing That The Sole Substantive Issue Between The Parties Is That Of Correctness Of The Learned Lower Authorities’ Action Assessing The Assessee’S Interest Component Of Land Acquisition Compensation U/S 28 Of The Land Acquisition Act, 1894, While Invoking Section 57(Iv) R.W.S. 56(1)(A) R.W.S. 145A(B) Of The Act. 4. Learned Sr. Dr Representing The Department Vehemently Argued That The Instant Issue Is No More Res Integra In Light Of Mahender Pal Narang Vs. Cbdt (2020) 423 Itr 13 (P&H) As Well As Pcit Vs. Inderjit Singh Sodhi Huf (2024) 161 Taxmann.Com 301 (Del.) Wherein The Department Has Succeeded Before Their Lordships That The Impugned Interest Component Ought To Be Assessed As Income From “Other” Sources Only.

Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 154Section 263Section 28Section 56(2)(viii)

…IN THE INCOME TAX APPELLATE TRIBUNAL, DELHI BENCH: ‘E’ NEW DELHI BEFORE SHRI SATBEER SINGH GODARA, JUDICIAL MEMBER AND SHRI MANISH AGARWAL, ACCOUNTANT MEMBER Assessment Year: 2018-19 Sh. Mahender Malik, Vs. Income Tax Officer, 388, Satroad Khurad, Near Ward-1, Adarsh High School, Hisar Hisar PAN: BITPM5341N (Appellant) (Respondent) Assessee by Ms. Karishma Rathore, Adv. Sh. Mayank Patawari, Adv. Department by Sh. Yogeshwar Sharma, Sr. DR Date of hearing 29.01.2026 Date of pronouncement 29.01.2026 ORDER PER SATBEER SINGH GODARA, JM This assessee’s appeal for assessment year 2018-19, arises against the Commissioner…

Krishan Kumar Yadav, Rewari vs. ITO, Ward-2, Rewari

In the result, appeal of the assessee is allowed

ITA 8417/DEL/2025[2020-21]Status: DisposedITAT Delhi20 Jan 2026AY 2020-21

Bench: Sh. Satbeer Singh Godaraita No. 8417/Del/2025 : Asstt. Year: 2020-21 Krishan Kumar Yadav, Vs Income Tax Officer, Bank Of Baroda, Circular Road, Ward-2, Rewari, Haryana-123401 Rewari, Haryana-123401 (Appellant) (Respondent) Pan No. Aabpy1644F Assessee By: Sh. I. P. Bansal, Adv. & Sh. Vivek Bansal, Adv. Revenue By : Sh. Manoj Kumar, Sr. Dr Date Of Hearing: 20.01.2026 Date Of Pronouncement: 20.01.2026 Order This Assessee’S Appeal For Assessment Year 2020-21 Arises Against The Cit(A)/Nfac, Delhi’S Din & Order No. Itba/Nfac/S/250/2025-26/1081822094(1) Dated 16.10.2025, In Proceedings U/S 147 Of The Income Tax Act, 1961 (In Short “The Act”).

For Appellant: Sh. I. P. Bansal, Adv. &For Respondent: Sh. Manoj Kumar, Sr. DR
Section 10(37)Section 142(1)Section 143Section 143(1)(a)Section 143(2)Section 143(3)Section 147Section 263Section 28Section 56(2)(viii)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘SMC’, NEW DELHI Before Sh. Satbeer Singh Godara, Judicial Member ITA No. 8417/Del/2025 : Asstt. Year: 2020-21 Krishan Kumar Yadav, Vs Income Tax Officer, Bank of Baroda, Circular Road, Ward-2, Rewari, Haryana-123401 Rewari, Haryana-123401 (APPELLANT) (RESPONDENT) PAN No. AABPY1644F Assessee by: Sh. I. P. Bansal, Adv. & Sh. Vivek Bansal, Adv. Revenue by : Sh. Manoj Kumar, Sr. DR Date of Hearing: 20.01.2026 Date of Pronouncement: 20.01.2026 ORDER This assessee’s appeal for Assessment Year 2020-21 arises against the CIT(A)/NFAC, Delhi’s DIN & order No. ITBA/NFAC/S…