Satish Chandra Gupta v. Assessing Officer

54 ITD 508Income Tax Appellate Tribunal1995#14329 most cited

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2025.

Sections most often in play

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

Issues it is cited on

section 54f section 54 transfer prescribed india total income document

Judgments citing Satish Chandra Gupta v. Assessing Officer

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

…he residential house should be completed within the prescribed period 16 and benefit under section 54F was allowed. It was further held that thrust was on investment and not on completion. viii) In the case of Satish Chandra Gupta v. Assessing Officer [1995] 54 ITD 508 (ITAT, Delhi Bench) where the assessee had purchased a site and could not complete the construction of the house within the prescribed period of three years and the house was constructed and completed subsequently, the Delhi Bench granted relief on the ground that the delay had occurred on account of reasons beyond the control of the assessee. ix)…

INDIRA GIRI,JAIPUR vs. ASSESSING OFFICER, INCOME TAX DEPARMENT JAIPUR

The appeal of the assessee is allowed

ITA 511/JPR/2023[2016-17]Status: DisposedITAT Jaipur02 Jan 2024AY 2016-17

Bench: The Due Date Of Furnishing Itr, Therefore Deposit In Capital Gain Account For Compliance U/S 54(2) Was Impossible On The Part Of The Assessee.

For Appellant: Shri Sandeep Manik (C.A.)For Respondent: Shri Anup Singh (Addl.CIT) a

Section 142(1)Section 143(1)Section 143(2)Section 143(3)Section 54Section 54(2)Section 54F

…be completed within the prescribed period and benefit under s. 54F was allowed. It was held that thrust was on investment and not on completion. 3. Satish Chandra Gupta The facts of this case were, the vs. Assessing Officer, assessee had purchased a site and 54 ITD 508 (ITAT, Delhi could not complete the construction Bench) of the house within the prescribed period of three years. However, the house was constructed and completed subsequently. Relief was given on the ground that the delay had occurred on account of reasons beyond the control of the assessee. 4. Narasimha Raju Rudra 1. Provision contained Rao vs.…

DHANANJAY MADHUKAR NAIK,MUMBAI vs. ITO 12(3)(3), MUMBAI

In the result, appeal filed by the assessee is allowed

ITA 2988/MUM/2022[2017-2018]Status: DisposedITAT Mumbai09 Aug 2023AY 2017-2018

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Bledhananjay Madhukar Naik V. Ito 12(3)(3) 306, Meghdoot Chsl, Sahaji Raje Marg Room No. 1631, 16Th Floor Koldongri, Vile Parle (W) Air India Building, Nariman Point Mumbai- 400057 Mumbai- 400021 Pan: Alrpn7498M (Appellant) (Respondent) Assessee Represented By : Shri Anil Masand Department Represented By : Shri P.D. Chougule

Section 54Section 54ESection 54F

…ecause the sale deed had not been executed or that construction is not complete, and it is not in a fit condition to be occupied does not disentitle the assessee to claim section 54F relief. 7.13 In the case of Satish Chandra Gupta v. Assessing Officer (1995) 54 ITD 508 (ITAT, Delhi Bench) (Placed at PB Page No. 215- 228) where the assessee had purchased a site and could not complete the construction of the house within the prescribed period of three years and the house was constructed and completed subsequently, the Delhi Bench granted relief on the ground that the delay had occurred on account of reasons beyond…

SHALINI ANAND MURTHY,MUMBAI vs. ACIT 17(3), MUMBAI

In the result, appeal of the assessee is dismissed

ITA 2404/MUM/2019[2011-12]Status: DisposedITAT Mumbai12 Jan 2023AY 2011-12

Bench: Shri Aby T Varkey () & Shri Om Prakash Kant () Assessment Year: 2011-12

For Appellant: Shri.Srinivas S KotaFor Respondent: Shri Satyapal Kumar, Sr.AR

Section 143(3)Section 147Section 54F

…on following following judicial judicial pronouncements:- 1. T Shiva Kumar vs ITO 9158 ITD 329 (Bangalore Tribunal) T Shiva Kumar vs ITO 9158 ITD 329 (Bangalore Tribunal) T Shiva Kumar vs ITO 9158 ITD 329 (Bangalore Tribunal) 2. Satish Chandra Gupta vs AO (54 ITD 508) (Delhi Satish Chandra Gupta vs AO (54 ITD 508) (Delhi Satish Chandra Gupta vs AO (54 ITD 508) (Delhi Tribunal) 3. ACIT vs Kamlakar Moghe (378 ITR 561)(Bom.HC) vs Kamlakar Moghe (378 ITR 561)(Bom.HC) vs Kamlakar Moghe (378 ITR 561)(Bom.HC) 4. Sunil Kumar Saha vs ITO (156 ITD 1)(Kol.T Sunil Kumar Saha vs ITO (156 ITD 1)(Kol.T Sunil Kumar Saha vs I…

AVTAR KRISHEN JALLA,NEW DELHI vs. ITO WARD - 29(4), NEW DELHI

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

ITA 9859/DEL/2019[2012-13]Status: DisposedITAT Delhi28 May 2021AY 2012-13

Bench: Shri R.K. Pandaassessment Year: 2012-13 Avtar Krishen Jalla, Vs Ito, D-6, Pamposh Enclave, Ward 29(4), New Delhi. New Delhi. Pan: Aadpj6244N (Appellant) (Respondent) Assessee By : Shri Upender Bhatt, Fca Revenue By : Shri Farath Khan, Sr. Dr Date Of Hearing : 16.03.2021 Date Of Pronouncement : 28.05.2021 Order

For Appellant: Shri Upender Bhatt, FCAFor Respondent: Shri Farath Khan, Sr. DR

Section 147Section 148Section 151

…above proposition, he relied on the following decisions:- i. Bal Kishan Atal vs. ACIT, (2019) 176 ITD 0330 (Delhi-Trib); 5 ii. Mrs. Seetha Subramanian Vs. ACIT (1996) 59 ITD 0094 (Madras-Trib); iii. Satishchandra Gupta vs. AO (1995) 53 TTJ (Del) 578/(1995) 54 ITD 508 (Del); iv. CIT vs. Hilla J.B. Wadia (1995) 216 ITR 376 (Bom); 6. The ld. DR, on the other hand, heavily relied on the orders of the CIT(A). ] 7. I have considered the rival arguments made by both the sides, perused the orders of the AO and the CIT(A) and the paper book filed on behalf of the assessee. I have also considered the various decisions…

DR. RAJINDER KUMAR GUPTA,NEW DELHI vs. ACIT, NEW DELHI

In the result, appeal of the assessee is allowed

ITA 4089/DEL/2015[2009-10]Status: DisposedITAT Delhi31 Jan 2019AY 2009-10

Bench: Shri R.K. Panda & Shri K. Narasimha Chary

For Appellant: Shri Rajneesh Behari Mathur, CAFor Respondent: Ms Ashima Neb, Sr. DR

Section 143(3)Section 263Section 54Section 54o

…e reasons beyond the control of the assessee, denial is unjustified. He placed reliance on the decisions reported in the cases of (i) Bhavna Cuccria vs ITO, (Chd) 82 Taxmann.com 306; (ii) Smt. Shashi Verma vs CIT, 224 ITR 106 (MP); (iii) Satish Chandra vs AO, 54 ITD 508 (Del); (iv) CIT vs. SambandamUdaykumar, 19 Taxmann.com. 17 (kar); and (vi) Kishore H Galaiya vs ITO, 24 Taxmann.com 11 (Mum) for the principle that it would be incorrect to refuse the benefit u/s 54 of the Act on the ground that the new residential house was not complete within three years of sale of the old residential property. Suffice if the su…

RAJPAL TREHAN,NEW DELHI vs. ACIT, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 6113/DEL/2016[2013-14]Status: DisposedITAT Delhi05 May 2017AY 2013-14

Bench: Shri N. K. Saini

For Appellant: Sh. Raj Kumar Gupta &For Respondent: Ms. Bedobani, Sr. DR

Section 133B(1)Section 143(1)Section 234Section 54Section 54F

…IT Vs R. L. Sood 245 ITR 727 (Del.) " Smt. Shashi Verma 224 ITR 106 (MP) " Smt. Rajneet Sandhu Vs DCIT (2010) 133 TTJ 64 (Chd.) " Narsimha Raju Rudra Rao Vs ACIT 35 Taxman 90 (Hyd. Trib.) " Bajaj Tempo Ltd. Vs CIT 196 ITR 188 (SC) " Satish Chandra Gupta Vs AO 54 ITD 508 (Del. Trib.) " CIT Vs Smt. B. B. Shanthakumari 126 DTR 436 (Kar.) " Smt. Ranjneet Sandhu Vs DCIT 133 TTJ 64 (Chd.) " Narashimha Raju Rudra Raju Vs ACIT 35 Taxman 90 (Hyd. Trib.) " Satish Chandra Gupta Vs AO 54 ITD 508 (Del. Trib.) 10. In his rival submissions the ld. DR reiterated the observations made by the authorities below in their respective…