Sham Lal Narula (Dr.) v. CIT

53 ITR 151Supreme Court of India1964#1116 most cited

What is Sham Lal Narula (Dr.) v. CIT authority for?

Interest received under Section 28 of the Land Acquisition Act, 1894, on enhanced compensation does not form part of the compensation itself but is taxable as 'income from other sources', analogous to interest under Section 34 of the Act.

100

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2017 to 2026.

Also referred to as

Sham Lal Narula v. CIT · 53 ITR 151 · interest enhanced compensation · Section 28 Land Acquisition Act 1894 · not part of compensation · taxable income from other sources · Section 34 Land Acquisition Act · compulsory acquisition · Section 56(2)(viii) · Section 45(5) · taxability of interest · Supreme Court

Sections most often in play

Section 56(2)(viii)Section 10(37)Section 1961Section 57(iv)Section 45(5)Section 145ASection 1894Section 145B(1)

Issues it is cited on

section 2(viii)section 56(viii)section 45(5)(c)section 155(16)section 23(1a)section 45(5)(b)section 145b(1)section 104section 194lakeyman insurancesection 23(2)section 160

Judgments citing Sham Lal Narula (Dr.) v. CIT

JAGPAL,GURUGRAM vs. PR. COMMISSIONER OF INCOME TAX, FARIDABAD

In the result, appeal of assessee in ITA No

ITA 2092/DEL/2024[2018-19]Status: DisposedITAT Delhi16 Jan 2026AY 2018-19

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri D.S. Sidhu, CIT-DR
Section 10(37)Section 145ASection 148Section 263Section 263(1)Section 28Section 34Section 56(2)(viii)

…mpensation u/s 28 of LAA. This issue of taxability of interest received on enhanced compensation u/s 28 of LAA came up for consideration, way back in 1964, by a three judge bench of the hon’ble Supreme Court in the case of Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151]. The hon’ble Court considered the interest under Section 28 of the Act of 1894 to be analogous to the interest under Section 34 of the Act, and held that the same did not form part of compensation. The relevant extract of the said decision is culled out as under:- "9. ---As we have pointed out, earlier, as soon as the Collector has taken possessi…

BIR SINGH,FARIDABAD vs. INCOME TAX OFFICER, WARD 1(1), FARIDABAD

In the result, appeal of assessee in ITA No

ITA 3969/DEL/2025[2017-18]Status: DisposedITAT Delhi17 Dec 2025AY 2017-18

Bench: Shri Anubhav Sharma & Shri Naveen Chandra

For Appellant: NoneFor Respondent: Shri Rajesh Kumar Dhanesta, Sr. DR
Section 10(37)Section 28Section 34Section 56(2)(viii)

…mpensation u/s 28 of LAA. This issue of taxability of interest received on enhanced compensation u/s 28 of LAA came up for consideration, way back in 1964, by a three judge bench of the hon’ble Supreme Court in the case of Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151]. The hon’ble Court considered the interest under Section 28 of the Act of 1894 to be analogous to the interest under Section 34 of the Act, and Page 3 of 15 ITA No. 3969/DEL/2025 [A.Y 2017-18] Bir Singh Vs. The .I.T.O held that the same did not form part of compensation. The relevant extract of the said decision is culled out as under:- "9. ---A…

RANJIT SINGH,PANCHKULA vs. DEPUTY DIRECTOR, CPC DEPARTMENT

ITA 992/CHANDI/2025[2023-24]Status: DisposedITAT Chandigarh11 Nov 2025AY 2023-24

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…hrough the concerned amendment of 2010. Therefore, the said decision lacks any applicability in the facts and circumstances of the present case. 26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case of Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering the interest under Section 28 of the Act of 1894 to be analogous to the interest under Section 34 of the Act, took the view that the same did not form part of compensation. The relevant extract of the said decision is culled out as under:- "9. --- As we have pointed out, earlier, as soon as the Collector has taken possession of…

LABH SINGH,PANCHKULA vs. INCOME TAX OFFICER, WARD NO 2,, PANCHKULA

ITA 725/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9. --\nAs we have pointed out, earlier, as soon as the Collector has taken\nposses…

BHUPINDER SINGH,AMBALA vs. INCOME TAX OFFICER, W-1, AMBALA, AMBALA

ITA 528/CHANDI/2025[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15
For Respondent: \nShri Suraj Bhan Nain, Advocate

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9.\nAs we have pointed out, earlier, as soon as the Collector has taken\npossessio…

SH. HAKAM SINGH,PATIALA vs. INCOME TAX OFFICER, WARD-4, PATIALA

ITA 486/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9. --\nAs we have pointed out, earlier, as soon as the Collector has taken\nposses…

BALBIR SINGH,SIRSA, HARYANA vs. ITO, WARD-1, SIRSA, SIRSA, HARYANA

ITA 483/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9.\nAs we have pointed out, earlier, as soon as the Collector has taken\npossessio…

BISHAN CHAND,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5 (5), CHANDIGARH, CHANDIGARH

ITA 458/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9.\nAs we have pointed out, earlier, as soon as the Collector has taken\npossessio…

SAT PAL,CHANDIGARH vs. INCOME TAX OFFICER, WARD 5(5), , CHANDIGARH

ITA 243/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\"9.\nAs we have pointed out, earlier, as soon as the Collector has taken\npossession…

NARENDER KAUR,KURUKSHETRA, HARYANA vs. INCOME TAX OFFICER WARD-1 , KURUKSHETRA

ITA 165/CHANDI/2025[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Respondent: \nShri Suraj Bhan Nain, Advocate

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9.\nAs we have pointed out, earlier, as soon as the Collector has taken\npossessio…

BALVINDER SINGH,FATEHABAD vs. ITO WARD-1, FATEHABAD

ITA 153/CHANDI/2025[2013-14]Status: DisposedITAT Chandigarh11 Nov 2025AY 2013-14

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9. --\nAs we have pointed out, earlier, as soon as the Collector has taken\nposses…

GURDEEP SINGH HUF,CHANDIGARH vs. ITO, WARD 5(5), CHANDIGARH

ITA 1153/CHANDI/2025[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9. --\nAs we have pointed out, earlier, as soon as the Collector has taken\nposses…

JARNAIL SINGH,VILLAGE BHAGWANPUR, KALKA vs. ITO, WARD-2, PANCHKULA

ITA 1025/CHANDI/2025[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9. --\nAs we have pointed out, earlier, as soon as the Collector has taken\nposses…

BALJEET KAUR,NADI MOHALLA AMBALA CITY vs. ITO WARD 1, AMBALA, AMBALA

ITA 92/CHANDI/2024[2014-15]Status: DisposedITAT Chandigarh11 Nov 2025AY 2014-15

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9. --\nAs we have pointed out, earlier, as soon as the Collector has taken\nposses…

ARJESH KUMAR,PATIALA vs. ITO NATIONAL E-ASSESSMENT CENTRE , DELHI

ITA 876/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19
For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…hrough the concerned amendment of 2010. Therefore, the said decision lacks any applicability in the facts and circumstances of the present case. 26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case of Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering the interest under Section 28 of the Act of 1894 to be analogous to the interest under Section 34 of the Act, took the view that the same did not form part of compensation. The relevant extract of the said decision is culled out as under:- "9. --- As we have pointed out, earlier, as soon as the Collector has taken possession of…

KAKA SINGH ALIAS GULJAR SINGH,PATIALA vs. INCOME TAX OFFICER , PATIALA

ITA 663/CHANDI/2024[2020-21]Status: DisposedITAT Chandigarh11 Nov 2025AY 2020-21
For Respondent: \nShri Suraj Bhan Nain, Advocate

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9. --\nAs we have pointed out, earlier, as soon as the Collector has taken\nposses…

ANJU,MOHALI vs. INCOME TAX OFFICER WARD 6 (1) , MOHALI

ITA 563/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Appellant: \nShri Suraj Bhan Nain, AdvocateFor Respondent: \nShri Manav Bansal, CIT, DR

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9. --\nAs we have pointed out, earlier, as soon as the Collector has taken\nposses…

INCOME TAX OFFICER, FATEHABAD vs. MAHESH NAGPAL, FATEHABAD

ITA 531/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

Bench: SHRI. LALIET KUMAR (Judicial Member), SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Suraj Bhan Nain, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

…hrough the concerned amendment of 2010. Therefore, the said decision lacks any applicability in the facts and circumstances of the present case. 26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case of Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering the interest under Section 28 of the Act of 1894 to be analogous to the interest under Section 34 of the Act, took the view that the same did not form part of compensation. The relevant extract of the said decision is culled out as under:- "9. --- As we have pointed out, earlier, as soon as the Collector has taken possession of…

RAMKARAN ,PANCHKULA vs. NFAC, DELHI

Accordingly, finding no merit in the appeals, the same are hereby\ndismissed

ITA 503/CHANDI/2024[2015-16]Status: DisposedITAT Chandigarh11 Nov 2025AY 2015-16
For Respondent: \nShri Suraj Bhan Nain, Advocate

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9.\nAs we have pointed out, earlier, as soon as the Collector has taken\npossessio…

SARVAN SINGH,AMBALA vs. INCOME TAX OFFICER-WARD 4, AMBALA

ITA 458/CHANDI/2024[2018-19]Status: DisposedITAT Chandigarh11 Nov 2025AY 2018-19

…gh\nthe concerned amendment of 2010. Therefore, the said decision lacks any\napplicability in the facts and circumstances of the present case.\n26. Notably, a three-Judges Bench of the Hon'ble Supreme Court in the case\nof Sham Lal Narula (Dr.) v. CIT [(1964) 53 ITR 151], while considering\nthe interest under Section 28 of the Act of 1894 to be analogous to\nthe interest under Section 34 of the Act, took the view that the same did not\nform part of compensation. The relevant extract of the said decision is culled\nout as under:-\n\"9.\nAs we have pointed out, earlier, as soon as the Collector has taken\npossessio…

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