How many judgments cite Sanjeev Lal v. CIT?

122 judgments on BharatTax cite Sanjeev Lal v. CIT (365 ITR 389), spanning 2012 to 2026.

Which sections of the Income Tax Act does Sanjeev Lal v. CIT come up under?

It is most often cited in judgments turning on Section 143(3), Section 54, Section 147, Section 2(47), Section 148, Section 54F.

Sanjeev Lal v. CIT

365 ITR 389Supreme Court of India2014#867 most cited

What is Sanjeev Lal v. CIT authority for?

For claiming capital gains exemption under beneficial provisions like section 54, the 'date of transfer' can be the date of the agreement to sell, particularly when coupled with substantial advance consideration or an enforceable right, adopting a purposive and liberal interpretation to acknowledge the assessee's intent.

122

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2012 to 2026.

Also referred to as

Sanjeev Lal v. CIT · section 2(47) · section 54 · section 54F · date of transfer · agreement to sell · capital gains exemption · purposive interpretation · beneficial provision · long-term capital gain

Also reported as

46 Taxmann.com 300225 Taxmann 239

Sections most often in play

Section 143(3)Section 54 Section 147 Section 2(47)Section 148 Section 54F Section 250 Section 54B

Issues it is cited on

section 2(47)purposive interpretation section 53a section 53 section 54b date of transfer section 54 indexed cost of acquisition section 54f section 48 stamp duty value section 45

Judgments citing Sanjeev Lal v. CIT

ABC INDIA LIMITED,KOLKATA vs. DCIT, CIRCLE 11(1),, KOLKATA

In the result, the appeal of the assessee is allowed

ITA 2673/KOL/2025[2022-2023]Status: DisposedITAT Kolkata15 Apr 2026AY 2022-2023

Bench: Shri Rajesh Kumar, Am & Shripradip Kumar Choubey, Jm Abc India Limited Dcit, Circle 11(1) 40/8, Ballygunj, Circular Road, Aayakar Bhawan, Chowringhee Kolkata, West Bengal-700019 Square, Kolkata-700069 Vs. West Bengal (Appellant) (Respondent) Pan No. Aacca2035J Assessee By : Shri S.K. Pransukhka, Ar Revenue By : Shri Sanjib Kumar Paul, Dr Date Of Hearing: 16.02.2026 Date Of Pronouncement: 15.04.2026

For Appellant: Shri S.K. Pransukhka, ARFor Respondent: Shri Sanjib Kumar Paul, DR

Section 119Section 143(2)Section 143(3)Section 144BSection 14A

…India Limited; A.Y. 2022-23 required to be seen is whether this will qualify to be construed as transfer as defined under section 2(47) of the Act. 5. The Hon'ble Supreme Court in Sanjeev Lal v. CIT Sanjeev Lal v. CIT [2014] 46 taxmann.com 300/225 Taxman 239/365 ITR 389 (SC) (SC) considered this issue and the question which fell for consideration before the Hon'ble Supreme Court was whether the entire property (therein) can be said to have been sold at the time when an agreement to sell is entered into. The Hon'ble Supreme Court pointed out that in normal circumstances the afore-stated question has to be answere…

ITO WARD-53(3), NEW DELHI vs. ANJU MADHAN, NEW DELHI

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

ITA 9321/DEL/2019[2016-17]Status: DisposedITAT Delhi13 Mar 2026AY 2016-17

Bench: Shri S. Rifaur Rahman & Shri Vimal Kumar

Section 53ASection 54

…ITA No. 9321/Del/2019 IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRI VIMAL KUMAR, JUDICIAL MEMBER ITA No.9321 /Del./2019, A.Y. 2016-17 Income Tax Officer Vs. Anju Madhan Ward-53(3), E-108, Malcha Marg, New Delhi Diplomatic Enclave Chhanakya Puri, Delhi 110021 New Delhi PAN: AALPM2084K (Appellant) (Respondent) Assessee by Shri I.P.Bansal, Adv. Shri Vivek Bansal, Adv. Shri Vishal Chechi, Adv. Revenue by Ms. Harpreet Kaur Hansra, Sr. DR Date of Hearing 20/01/2026 Date of Pronouncement 13/03/2026 ORDER PER S. RIFAUR RAHMAN, AM The Revenue has…

HARJINDER SINGH,DERABASSI vs. INCOME TAX OFFICER, CHANDIGARH

In the result, appeal of the Assessee is allowed for statistical purposes

ITA 795/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh09 Mar 2026AY 2012-13

Bench: SHRI. RAJ PAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Vinayak Malhotra, C.A (Virtual)For Respondent: Shri Vivek Vardhan, Addl. CIT, Sr. DR

Section 143(3)Section 147Section 148Section 54BSection 56(2)(x)

…e said land as the vendee gets a legitimate right to enforce a specific performance of the agreement and the same would amount to transfer of a Capital asset. The issue has been considered by the Hon'ble Supreme Court, in the case of Sanjeev Lal v. CIT [2014] 365 ITR 389/225 Taxman 239/46 taxmann.com 300 (SC). 4. That the Ld. CIT erred in not considering the two-year usage of land to be reckoned from 03.02.2010, i.e, from the date of agreement to sell executed by the assessee and has failed to consider the reply furnished by the assessee, dated 2 17.02.2021, supported with the relevant documents, i.e, Fard Khasr…

HARBHAJAN SINGH,PUNJAB vs. COMMISSIONER OF INCOME TAX APPEAL, DELHI

In the result, the appeal of the Assessee stands allowed for statistical purposes

ITA 209/CHANDI/2025[2012-13]Status: DisposedITAT Chandigarh11 Feb 2026AY 2012-13

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 209/Chd/2025 "नधा"रण वष" / Assessment Year : 2012-13 Harbhajan Singh, The Ito, बनाम House No. 98, Ward 5 (5), Gazipur, Chandigarh Vs. Dhakaull Derabassi, Mohali 140603 "थायी लेखा सं./ Pan No: Eiups4243F अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Vinayak Malhotra, Ca राज"व क" ओर से/ Revenue By : Sh. Vivek Vardhan, Addl. Cit, Sr.Dr

For Appellant: Sh. Vinayak Malhotra, CAFor Respondent: Sh. Vivek Vardhan, Addl. CIT, Sr.DR

Section 143Section 548

…आयकर अपील"य अ"धकरण, च"डीगढ़ "यायपीठ, च"डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH, ‘A’, CHANDIGARH BEFORE SHRI LALIET KUMAR, JUDICIAL MEMBER & SHRI KRINWANT SAHAY, ACCOUNTANT MEMBER आयकर अपील सं./ ITA No. 209/CHD/2025 "नधा"रण वष" / Assessment Year : 2012-13 Harbhajan Singh, The ITO, बनाम House No. 98, Ward 5 (5), Gazipur, Chandigarh Vs. Dhakaull Derabassi, Mohali 140603 "थायी लेखा सं./ PAN NO: EIUPS4243F अपीलाथ"/Appellant ""यथ"/Respondent ( HYBRID HEARING ) "नधा"रती क" ओर से/Assessee by : Sh. Vinayak Malhotra, CA राज"व क" ओर से/ Revenue by : Sh. Vivek Vardhan, Addl. CIT, Sr.DR सुनवाई क" तार"ख/Dat…

RANAJIT SURESH RAJAMANE,SOLAPUR vs. ITO, WARD 1, PANDHARPUR, PANDHARPUR

In the result, the appeal of the assessee is allowed

ITA 1678/PUN/2024[2014-15]Status: DisposedITAT Pune13 Jan 2026AY 2014-15

Bench: Dr. Manish Borad & Ms. Astha Chandraआयकर अपील सं. / Ita No.1678/Pun/2024 धििाारण वर्ा / Assessment Year: 2014-15 Ranajit Suresh Rajamane, Vs Ito Ward 1, Shukrawar Peth, Pandharpur Tembhurni Madha Solapur- 413211 Maharashtra Pan-Bmepr3878N Appellant Respondent

For Appellant: Smt. Deepa KhareFor Respondent: Shri Aviyogi Ambadkar

Section 139Section 147Section 148Section 250Section 54Section 548Section 54BSection 54B(1)Section 69A

…54 of the Act, the registration of sale deed is not necessary. It is enough if the assessee has paid the consideration, acquired the possession with full rights and has fulfilled other requirements of the provisions of the Act:- 1. Sanjeev Lal v. CIT [2014] 365 ITR 389/225 Taxman 239/46 taxmann.com 300 (SC) 2. CIT. T.N. Aravinda Reddy [1979] 120 ITR 46/2 Tasman 541 (SC) 3. CIT. K. Jelani Basha [2002] 256 ITR 282/122 Taxman 509 (Mad) 4. CIT v. Ram Gopal (2015) 372 ITR 498/230 Taxman 205/55 taxmann.com 536 (Delhi) 5. Balraj V C77 [2002] 254 ITR 22/123 Tasman 290 (Delhi) 6. CIT. R.1. Sood (2000) 245 ITR 727/108 Ta…

POONAM DHANANJAY SANDU,NAVI MUMBAI vs. INCOME TAX OFFICER, NAVI MUMBAI

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

ITA 2050/MUM/2025[2017-18]Status: DisposedITAT Mumbai25 Nov 2025AY 2017-18

Bench: Shri Sandeep Gosain, () & Shri Girish Agrawal, ()

Section 143(3)Section 234BSection 250Section 270A(3)Section 270A(9)Section 54

…he buyer to seek specific performance in case of breach. 9. Judicial Precedents Supporting the Appellant's Claim: (Case Law Paper Book Submitted during the course of hearing) Sr. Particulars Page Relevant No. No Para 1 Sanjeev Lal Vs. CIT (2014) 1-16 Para 17- 365 ITR 389 (SC) 25 Pg 12- 16 2 CIT Vs. Shimbhu Mehra 17- Para 12- (2016) 236 Taxmann.com 16 14 pg 295 (All. HC) 25-26 3 Kishorbhai Harjibhai Patel 27- Para 13- Vs. ITO (2019) 107 51 38 pg taxmann.com 295 38-51 4 Gautam Jhunjhunwala Vs. 52- Para 6-8, ITO (2018) 173 ITD 93 (Kol 62 Pg 59-62 ITAT) Suit for specific performance can be enforced in case of agreeme…

DCIT(CC)-4(2), MUMBAI, MUMBAI vs. ASHISH MEHDIRATTA, LUCKNOW, UTTAR PRADESH, INDIA

The appeal of the revenue is dismissed

ITA 3568/MUM/2025[2021-22]Status: DisposedITAT Mumbai13 Nov 2025AY 2021-22

Bench: Shri Pawan Singh, Jm & Ms Padmavathy S, Am

For Appellant: Shri Kalrav Mehrotra, ARFor Respondent: Shri Surendra Mohan, Sr. DR

Section 250Section 54

…ht arising out of the letter of allotment can be surrendered or case in hand before us. 15. For the aforesaid understanding, we gainfully rely on the decision of Hon'ble Supreme Court in the case of Sanjeev Lal v. CIT [2014] 46 taxmann.com 300/225 Taxman 239/365 ITR 389 wherein similar observations and findings were given by the Hon'ble Apex Court, though in the context of agreement to sell. In paragraph 23 of the said decision, it is held as under: “23. Consequences of execution of the agreement to sell are also very clear and they are to the effect that the appellants could not have sold the property to someon…

DIMPLE RAJESH OSWAL,PUNE vs. INCOME TAX OFFICER WARD 5(1), PUNE

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

ITA 1506/PUN/2025[2016-17]Status: DisposedITAT Pune14 Oct 2025AY 2016-17

Bench: Shri R. K. Pandaassessment Year : 2016-17

For Appellant: Shri Bharat ShahFor Respondent: Ms. Sailee Dhole, JCIT

Section 143(2)Section 143(3)Section 148Section 148ASection 56(2)(vii)

…IN THE INCOME TAX APPELLATE TRIBUNAL PUNE BENCH “SMC”, PUNE BEFORE SHRI R. K. PANDA, VICE PRESIDENT Assessment Year : 2016-17 Dimple Rajesh Oswal ITO, Ward 5(1), Pune 585-9. Sandesh Society, Salisbury Vs. Park, Market Yard, Pune – 411037 PAN : ABCPO7067J (Appellant) (Respondent) Assessee by : Shri Bharat Shah Department by : Ms. Sailee Dhole, JCIT (through virtual) Date of hearing : 23-09-2025 Date of pronouncement : 14-10-2025 O R D E R PER R. K. PANDA, VP : This appeal filed by the assessee is directed against the order dated 23.05.2025 of the Ld. CIT(A) / NFAC, Delhi, relating to assessment year 2016-17.…

MAIMOON FASHION ACCESSORIES PRIVATE LIMITED,MUMBAI vs. INCOME TAX OFFICER, WARD 7(2)(1), MUMBAI, MUMBAI

In the result, the appeal by the assessee is allowed

ITA 5010/MUM/2025[2016-17]Status: DisposedITAT Mumbai26 Sept 2025AY 2016-17

Bench: Shri Narendra Kumar Billaiyashri Sandeep Singh Karhailmaimoon Fashion Accessories Pvt. Ltd., 645, Maimoon House, Mohili Village, A.K. Road, J.B. Nagar S.O., Mumbai – 400059 ............... Appellant Pan : Aaccm3307P

For Appellant: Ms. Rupal KakuFor Respondent: Shri Rajiv Kadam, Sr.DR

Section 2(47)Section 2(47)(ii)Section 250Section 271(1)(c)Section 45

…executed on 11.03.2016, the plot of land was already transferred to the purchaser in the financial year 2009-10 and thus, for all intents and purposes, the land was transferred in the assessment year 2010- 11. 13. We find that in Sanjeev Lal vs CIT, in [2014] 365 ITR 389 (SC), the Hon’ble Supreme Court, while dealing with the facts, wherein the assessee claimed the benefit under section 54 of the Act in respect of the capital gains arising from transfer of property vide sale deed registered on 24.09.2004, while the agreement to sell was executed on 27.09.2002, considered the 10 question as to whether the date on…

RAJNI KUMAR WIFE OF SHRI BRIG. NARENDER KUMAR H.NO.394, SECTOR-21, GURGAONN,GURGAON vs. THE INCOME TAX OFFICER WARD-3(1), GURGAON, GURGAON

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

ITA 3188/DEL/2023[2017-2018]Status: DisposedITAT Delhi17 Sept 2025AY 2017-2018

Bench: Shri S.Rifaur Rahman & Shri Vimal Kumarrajni Kumar, Vs. Ito, Ward 3 (1), W/O Shri Brig. Narender Kumar, Gurgaon. House No.394, Sector 21, Gurgaon – 122 001 (Haryana). (Pan : Ayypk1781A) (Appellant) (Respondent) Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Shri Rajesh Kumar Dhanesta, Sr. Sr Date Of Hearing : 19.08.2025 Date Of Order : 17.09.2025 O R D E R Per S.Rifaur Rahman,Am: 1. The Assessee Has Filed Appeal Against The Order Of The Learned Commissioner Of Income-Tax (Appeals)/National Faceless Appeal Centre (Nfac), Delhi [“Ld. Cit(A)”, For Short] Dated 27.09.2023 For The Assessment Year 2017-18 & The Assessment Order Was Passed Under Section 143(3) R.W.S. 263 Of The Income-Tax Act, 1961 (For Short ‘The Act’).

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. SR

Section 143(3)Section 263Section 54Section 54F

…on as provided under the law. Now if the developer after receiving the money could not fulfill the obligation within time, then can assessee be held responsible for not complying the law. 10. The Hon’ble Supreme Court in the case of Sanjeev Lal Vs. CIT [2014] 365 ITR 389 (SC) has laid down the purposive interpretation of section 54 to give a liberal approach to the assessee who clearly intended to claim benefit of section 54. Their Lordships held that section 54 is a beneficial provision and is to be construed keeping in view the intention of the Legislature to give relief in the matter of payment of tax on the l…

PAYAL KISHORE KULCHANDANI ,MUMBAI vs. INCOME TAX OFFICER 22(2)(5), MUMBAI

In the result, appeal of the assessee is allowed

ITA 3647/MUM/2025[2012-13]Status: DisposedITAT Mumbai18 Aug 2025AY 2012-13

Bench: Shri Amit Shukla & Smt. Renu Jauhriआयकर अपील सुं./Ita No. 3647/Mum/2025 (नििाारण वर्ा / Assessment Year: 2012-2013) Payal Kishore Kulchandani V/S. Income Tax Officer 1201, Badrinath, Opp. Khar बिाम Ward22(2)(5), Gymkhana, 15Th Road, Mumbai Khar West, Mumbai 400052. Piramal Chamber, Lalbaug,Parel, Mumbai - 400012. स्थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aappk0518C Appellant/अपीलार्थी .. Respondent/प्रनिवादी निर्ााररती की ओर से /Assessee By: Shri Vijay Mehta राजस्व की ओर से /Revenue By: Shri Virabhadra S. Mahajan

For Appellant: Shri Vijay MehtaFor Respondent: Shri Virabhadra S. Mahajan

Section 143(3)Section 250Section 54

…nd the date of registration for purchase of new property beyond the purchases period of one year prior to and two years after the sale of old property. 5. Ld. AR has also relied on judgement of the Hon’ble Apex Court in the case of Sanjeev Lal V. CIT [2014] (365 ITR 389) (SC) wherein the meaning of term ‘transfer’ was examined in the context of provisions of section 54 of the Act. The relevant observations of the Hon’ble Apex Court relied upon by the Ld. AR are reproduced below: “In addition to the fact that the term “transfer” has been defined under section 2(47) of the Act, even if looked at the provisions of…

NEERU ARORA,CHANDIGARH vs. CIRCLE-1, INTERNATIONAL TAXATION, CHANDIGARH

In the result, the appeal of the assessee is partly allowed in terms indicated above

ITA 60/CHANDI/2024[2013-14]Status: DisposedITAT Chandigarh25 Jun 2025AY 2013-14

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Smt. Tarundeep Kaur, CIT, DR

Section 142(1)Section 144C(2)Section 147Section 148Section 2(47)(v)Section 48Section 50CSection 50C(1)Section 50C(2)Section 53A

…s handed over and full consideration was received. It was submitted that the registration of the sale deed in A.Y. 2013-14 was only a procedural formality. Reliance was placed on the judgment of Hon’ble Supreme Court in the case of Sanjeev Lal vs. CIT [(2014) 365 ITR 389 (SC)]. 9. Without prejudice, the assessee submitted that in case the transaction was considered in A.Y. 2013-14, then in light of the first proviso to section 50C(1) inserted by the Finance Act, 2016, the stamp valuation as on the date of the agreement (20.02.2010) should be adopted since the entire sale consideration was received by account pay…

BRAJ KISHORE SINGH,ANDHERI EAST vs. ASSESSING OFFICER INT. TAX WARD 4(2)(1), INTERNATIONAL TAX, MUMBAI

In the result, the appeal is accordingly partly allowed for statistical

ITA 1011/MUM/2025[2015-16]Status: DisposedITAT Mumbai23 Jun 2025AY 2015-16

Bench: Ms. Padmavathy S & Shri Raj Kumar Chauhanbraj Kishore Singh Vs. Assessing Officer 604, Lantana, Nahar Amrit Internatinal Tax Ward Shakti, Chandivali, 4(2)91) Maharashtra -400 072. Room No. 632, Kautilya Bhavan, Pan: Bqips8474H C-41 To C-43, G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051

Section 142(1)Section 144C(1)Section 144C(2)Section 144C(5)Section 147Section 148Section 271(1)(c)Section 274

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “I”, MUMBAI BEFORE MS. PADMAVATHY S, ACCOUNTANT MEMBER AND SHRI RAJ KUMAR CHAUHAN, JUDICIAL MEMBER Braj Kishore Singh Vs. Assessing Officer 604, Lantana, Nahar Amrit Internatinal Tax Ward Shakti, Chandivali, 4(2)91) Maharashtra -400 072. Room No. 632, Kautilya Bhavan, PAN: BQIPS8474H C-41 to C-43, G Block, Bandra Kurla Complex, Bandra (East), Mumbai-400051 (Appellant) (Respondent) Assessee Represented by : Shri Suresh Kumar Gundher / Shri Abhishek Bothra, Ld. ARs. Department Represented by : Shri Krishna Kumar, Ld. DR Date of conclusion of Hearing : 16.06.2025 Da…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1(1)(1), MEERUT, MEERUT vs. PREM SAPRA, NEW DELHI

The appeal of the revenue is dismissed

ITA 1739/DEL/2024[2021-22]Status: DisposedITAT Delhi20 Jun 2025AY 2021-22

Bench: Smt. Annapurna Gupta & Ms. Madhumita Royassessment Year: 2021-22

Section 143(3)Section 54

…nly the Delhi High Court judgment in Kuldeep Singh as referred to by CIT(A) but also by following other judgments of Supreme Court, High Court and ITAT, which were duly noted and reproduced by CIT(A) in his appellate order. 8 ACIT v. Prem Sapra A.Y. 2021-22 ➤365 ITR 389, Sanjeev Lal and Smt. ShailMotil Lal vs. CIT (Supreme Court) Relevant observations and findings of the Apex Court from paras 20, 22, 23, 24 & 25 are reproduced below: “20. The question to be considered by this Court is whether the agreement to sell which had been executed on 27th December, 2002 can be considered as a date on which the property i…

ANAND BODDAPATY,HYDERABAD vs. DCIT., CIRCLE-5(1), HYDERABAD

In the result, appeal of the Assessee is dismissed

ITA 375/HYD/2025[2021-22]Status: DisposedITAT Hyderabad09 Jun 2025AY 2021-22

Bench: Shri Vijay Pal Rao & Shri Manjunatha G

For Appellant: CA Kumar Pal TatedFor Respondent: Sri Narender Kumar Naik

Section 142(1)Section 143(2)Section 263Section 45Section 54Section 54F

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD “B” BENCH: HYDERABAD BEFORE SHRI VIJAY PAL RAO, VICE PRESIDENT AND SHRI MANJUNATHA G, ACCOUNTANT MEMBER ITA.No.375/Hyd./2025 Assessment Year 2021-2022 Anand Boddapaty, The PCIT, Hyderabad-4, Hyderabad – 500 034. [vs. Hyderabad – 500 004. PAN ADKPB3810C (Appellant) (Respondent) For Assessee : CA Kumar Pal Tated For Revenue : Sri Narender Kumar Naik, CIT-DR Date of Hearing : 05.06.2025 Date of Pronouncement : 09.06.2025 ORDER PER MANJUNATHA G. : This appeal has been filed by the assessee against the order dated 13.02.2025 of the learned Principal Commissioner of Inco…

PREM SINGH RAJA ,CHAMBA vs. PRINCIPLE COMMISSIONER OF INCOME TAX -1, CHANDIGARH

In the result, both the above appeals filed by the assessee are allowed

ITA 423/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh04 Jun 2025AY 2015-16

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ajay Jain, CA and Shri Lovesh Bansal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

Section 263

…d acquired enforceable rights under the agreements. These payments were made in lieu of site development services and relinquishment of rights and were not received or receivable by the assessee. 3.3 The AR relied on the judgment in Sanjeev Lal v. CIT [(2014) 365 ITR 389 (SC)] to argue that agreement to sell confers enforceable rights. Reliance was also placed on K.P. Varghese v. ITO (131 ITR 597), Paramjit Singh v. ITO (323 ITR 588), and Malabar Industrial Co. Ltd. v. CIT (243 ITR 83) to contend that no real income accrued to the assessee and there was no prejudice to the Revenue. 3.4 It was further pointed out…

SH. PREM SINGH RAJA,CHAMBA vs. PR. C.I.T. -1, CHANDIGARH

In the result, both the above appeals filed by the assessee are allowed

ITA 359/CHANDI/2022[2017-18]Status: DisposedITAT Chandigarh04 Jun 2025AY 2017-18

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. MANOJ KUMAR AGGARWAL (Accountant Member)

For Appellant: Shri Ajay Jain, CA and Shri Lovesh Bansal, C.AFor Respondent: Smt. Kusum Bansal, CIT, DR (Virtual Mode)

Section 263

ARVINDBHAI RAMNIKLAL RAVAL HUF,SURAT vs. INCOME TAX OFFICER, WARD-1(3)(6), SURAT, SURAT

In the result, appeal of assessee is allowed

ITA 19/SRT/2024[2017-18]Status: DisposedITAT Surat28 Apr 2025AY 2017-18

Bench: Shri Pawan Singh & Shri Bijayananda Prusethआयकर अपील सं./Ita No.19/Srt/2024 Assessment Year: (2017-18) (Physical Court Hearing) Arvindbhai Ramniklal Raval Income Tax Officer, Ward- बनाम/ (Huf)308, Chhapania Street, 1(3)(6), Surat, Room No.303, 3Rd Vs. Adajan, Surat-395 009 Floor, Income Tax Office, Anavil Business Centre, Adajan Hazira Road, Adajan, Surat-395 009 "थायीलेखासं./जीआइआरसं./Pan/Gir No: Aaeha 1847 D (अपीलाथ"/Appellant) (""थ" /Respondent)

Section 143(3)Section 194ISection 250Section 54F

…IN THE INCOME-TAX APPELLATE TRIBUNAL, SURAT BENCH, SURAT BEFORE SHRI PAWAN SINGH, JUDICIAL MEMBER & SHRI BIJAYANANDA PRUSETH, ACCOUNTANT MEMBER आयकर अपील सं./ITA No.19/SRT/2024 Assessment Year: (2017-18) (Physical court hearing) Arvindbhai Ramniklal Raval Income Tax Officer, Ward- बनाम/ (HUF)308, Chhapania Street, 1(3)(6), Surat, Room No.303, 3rd Vs. Adajan, Surat-395 009 Floor, Income Tax Office, Anavil Business Centre, Adajan Hazira Road, Adajan, Surat-395 009 "थायीलेखासं./जीआइआरसं./PAN/GIR No: AAEHA 1847 D (अपीलाथ"/Appellant) (""थ" /Respondent) िनधा"रती की ओर से /Appellant by Shri Sapnesh R Sheth, CA राज" की…

SHRI PRINCEPREETJIT SINGH,RANJIT NAGAR vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the assessee is allowed

ITA 54/CHANDI/2021[2015-16]Status: DisposedITAT Chandigarh21 Apr 2025AY 2015-16

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Parikshit Aggarwal, C.AFor Respondent: Shri Chandrajit Singh, CIT, DR(Virtual)

Section 143(3)Section 263Section 54BSection 54F

…alifies u/s 54B. It is settled law that starting point for eligible investment u/s 54B is to be taken from the date of receipt of advance or agreement and the Ld. PCIT has erred in holding it otherwise. The Hon’ble Supreme Court in Sanjeev Lal vs. CIT [(2014) 365 ITR 389 (SC)] laid down that the date of transfer is to be reckoned from the date of agreement to sell, especially where substantial rights are transferred and possession or part payment has occurred. Similarly, 7 the Hon’ble Gujarat High Court in KishorebhaiHarjibhai Patel vs. ITO [(2019) 414 ITR 182 (Guj.)] reaffirmed and ruled that for computing the…

TAMAL KUNDU vs. ADDITIONAL/JOINT/DEPUTY/ASSISTANT VOMMISSIONER OF INCOME TAX NATIONAL E ASSESSMENT CENTRE DELHI

The appeal is allowed

ITAT/50/2025HC Calcutta11 Apr 2025

Bench: : The Hon'Ble The Chief Justice T.S Sivagnanam -A N D- The Hon'Ble Justice Chaitali Chatterjee (Das) Date : 11Th April, 2025.

Section 2(47)(ii)Section 2(47)(vi)Section 260ASection 56(2)(x)

…production in the rice mill. If such is the nature of the transaction what is required to be seen is whether this will qualify to be construed as transfer as defined under section 2(47) of the Act. The Hon’ble Supreme Court in Sanjeev Lal vs. CIT, (2014) 365 ITR 389 (SC) considered this issue and the question which fell for consideration before the Hon’ble Supreme Court was whether the entire property (therein) can be said to have been sold at the time when an agreement to sell is entered into. The Hon’ble Supreme Court pointed out that in normal circumstances the afore-stated question has to be answer…

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