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“Section 45(2)”

Section References (mined)Section 45Section 45(2)75 judgments

The decision most relied on for Section 45(2) is CIT v. B.C. Srinivasa Setty (128 ITR 294), cited in 628 judgments on BharatTax.

Leading authorities on Section 45(2)

CIT v. B.C. Srinivasa Setty
128 ITR 294 · 1981 · Supreme Court
628
citing judgments

When the cost of acquisition of a capital asset cannot be determined, the computation mechanism for capital gains fails, and thus no capital gains can be charged. This establishes a broader principle that a charging section cannot operate in the absence of specific machinery provisions for computation.

CIT v. Ghanshyam (HUF)
315 ITR 1 · 2009 · Supreme Court
363
citing judgments

Interest received under Section 28 of the Land Acquisition Act, 1894, is considered part of the enhanced compensation on compulsory acquisition of land. It is taxable as 'capital gains' and not separately as 'interest income' under the head Income from Other Sources.

Rama Bai v. CIT
181 ITR 400 · 1990 · Supreme Court
258
citing judgments

Interest income is taxable on either an accrual or cash basis, determined by accounting principles. This method was applicable prior to legislative changes that simplified the taxation of interest income.

CIT v. Balbir Singh Maini
398 ITR 531 · 2017 · Supreme Court
228
citing judgments

A transfer of immovable property, for the purpose of capital gains under section 2(47)(v) of the Income-tax Act, occurs only when the agreement allowing possession in part performance of a contract is a registered instrument, as mandated by Section 53A of the Transfer of Property Act.

CIT v. Govindbhai Mamaiya
91 Taxmann.com 20 · 2018 · Supreme Court
205
citing judgments

Interest on enhanced compensation received under Section 28 of the Land Acquisition Act, 1894, is considered part of the compensation, not merely interest income, and is exigible to tax on a receipt basis.

CIT v. Sohana Woollen Mills
296 ITR 238 · 2008 · High Court
180
citing judgments

A mere audit objection, by itself, is insufficient to infer that an Assessing Officer's order is erroneous or prejudicial to the interest of the Revenue for the purpose of initiating revisional proceedings.

Mahender Pal Narang v. CBDT
161 Taxmann.com 301 · 2024 · High Court
178
citing judgments

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).

CIT v. Hindustan Coca Cola Beverages P Ltd.
331 ITR 192 · 2011 · High Court
152
citing judgments

The Principal Commissioner of Income Tax cannot exercise revisional jurisdiction under Section 263 if the Assessing Officer has taken one of two possible views on a debatable issue during assessment proceedings.

Judgments citing Section 45(2)

M/S Dharani Developers Private Limited, Alwarpet, Chennai vs. ACIT, Company Circle 1(4), Nungambakkam Chennai

ITA 397/CHNY/2023[2008-2009]Status: DisposedITAT Chennai18 Jan 2024AY 2008-2009

Bench: Shri V. Durga Rao & Shri G. Manjunathaआयकर अपील सं./I.T.A. Nos.397, 398, 399, 400 & 401/Chny/2023 Assessment Years: 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18 M/S. Dharani Developers Private Vs. The Asst/Deputy Commissioner Of Limited, No. 1, Venus Colony Ii Street, Income Tax, Corporate Circle 1(1), Alwarpet, Chennai 600 018. 121, Mahatma Gandhi Road, [Pan:Aabcd6222D] Nungambakkam, Chennai 600 034. (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri K. Ramakrishnan, Ca ""थ" की ओर से/Respondent By : Shri D. Hema Bhupal, Jcit सुनवाई की तारीख/ Date Of Hearing : 09.01.2024 घोषणा की तारीख /Date Of Pronouncement : 18.01.2024 आदेश /O R D E R Per V. Durga Rao: This Appeal Filed By The Assessee Is Directed Against Separate Orders Of The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi, All Dated 31.01.2023 Relevant To The Assessment Years 2008-09, 2012-13, 2013-14, 2016-17 & 2017-18. 2. Brief Facts Of The Case Are That The Assessee Is Engaged In The Business Of Property Development & Filed Its Return Of Income For The Assessment Years Under Appeal. The First Ground Raised By The Assessee

For Appellant: Shri K. Ramakrishnan, CAFor Respondent: Shri D. Hema Bhupal, JCIT

this issue and remit the matter back to the file of the Assessing Officer to examine and compute the property under section 45(2) of the Act keeping in view of the above observation and decide the issue afresh in accordance with law after affording reasonable opportunity of being heard

Guruvendra Singh, Kota vs. Assistant Commissioner of Income Tax Circle-1, Kota

In the result, appeal of the assessee is allowed

ITA 144/JPR/2023[2016-17]Status: DisposedITAT Jaipur07 Dec 2023AY 2016-17

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Rohan Sogani (CA)For Respondent: Sh. A. S. Nehra (Addl. CIT) a
Section 142(1)Section 143(2)Section 143(3)Section 548Section 54B

stock in trade and prior to such sale i.e. gains till the date of conversion, was computed by the assessee in terms of Section 45(2) of ITA. 1.5. Thereafter, as and when such stock in trade was sold to the ultimate buyer, capital gains and corresponding business income ... year in which such stock in trade was ultimately sold by the assessee. The same was in accordance with Section 45(2) of the ITA. 1.6. Working in this regard, offering the gains on sale of part of the land, in the form of Capital Gains and Business Income

Anil Shankar Palewar, Nagpur vs. Income Tax Officer, Ward-5(1), Nagpur

In the result, appeal of the assessee is allowed

ITA 36/NAG/2022[2015-16]Status: DisposedITAT Nagpur31 Oct 2023AY 2015-16

Bench: Shri Satbeer Singh Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.36/Nag/2022 िनधा"रण वष" / Assessment Year : 2015-16 Anil Shankar Palewar, The Income Tax Officer, Plot No.219, Suyog Nagar, V Ward-5(1), Nagpur. Nagpur – 440015. S Pan: Abzpp 8221 A Appellant / Assessee Respondent / Revenue Assessee By Shri Kapil Hirani – Ar Revenue By Smt. Rashmi Mathur – Sr.Dr Date Of Hearing 26/10/2023 Date Of Pronouncement 31/10/2023 आदेश/ Order Per Dr. Dipak P. Ripote, Am: This Appeal Is Filed Against The Order Of Ld. Commissioner Of Income Tax[Nfac], Delhi Dated 26.12.2021Under Section 250 Of The Act, 1961 For The Assessment Year 2015-16. The Assessee Has Raised Following Grounds Of Appeal : “1) On The Facts & Circumstances Of The Case & In Law, The Ld. Ao Grossly Erred In Disallowing & The Ld. Cit(A) Nfac, Delhi Grossly Erred In Confirming The Denial Of Benefit Of Exemption Under Section 54Ec Of The Income Tax Act, 1961 As Claimed By The Appellant In His Return Of Income. The Exemption Under Section 54Ec Anil Shankar Palewar [A]

Section 250Section 54ESection 54F

capital asset into stock-in- trade. Such capital gain would arise in the year of conversion, so however, in terms of section 45(2) of the Act, its taxability is postponed to the year in which such stock-in-trade is actually sold or otherwise transferred by the assessee ... 54EC of the Act should be taken from the date such stock-in-trade is sold or otherwise transferred in terms of section 45(2) of the Act, though the taxability of capital gain was on the basis of 'transfer' as understood in section 45(2) of the Act. Therefore

Assistant Commissioner of Income Tax, Circle 1(1), Raipur vs. Meserss T.C. Buildcon Private Limited, Raipur

In the result CO filed by the assessee is allowed and the appeal filed by the revenue stands dismissed

ITA 173/RPR/2019[2011-12]Status: DisposedITAT Raipur27 Oct 2023AY 2011-12

Bench: Shri Ravish Sood, Jm & Shri Arun Khodpia, Am Assistant Commissioner Of Vs M/S. Tc Buildcon Pvt. Ltd. Income Tax, Circle 1(1) Vasudev, B-5, Sector-5, Raipur, (C.G.) Devendra Nagar, Raipur (C.G.) Pan: Aacct4516F Cross Objection No. 26/Rpr/2019 (Arising Out Of Ita No. 173/Rpr/2019) (िनधा"रण वष" / Assessment Year : 2011-12) Assistant Commissioner Of Vs M/S. Tc Buildcon Pvt. Ltd. Income Tax, Circle 1(1) Vasudev, B-5, Sector-5, Raipur, (C.G.) Devendra Nagar, Raipur (C.G.) Pan: Aacct4516F (अपीलाथ" /Appellant) (""यथ" / Respondent) .. िनधा"रती क" ओर से /Assessee By : Shri Sunil Kumar Agrawal, Ca राज"व क" ओर से /Revenue By : Shri V.K. Singh, Cit-Dr सुनवाई क" तार"ख / Date Of Hearing : 16-08-2023 घोषणाक" तार"ख/Date : 27-10-2023 Of Pronouncement आदेश / O R D E R Per Arun Khodpia, Am:

For Appellant: Shri Sunil Kumar Agrawal, CAFor Respondent: Shri V.K. Singh, CIT-DR
Section 142(1)Section 144Section 147Section 148

escaped income of Rs. 1,92,42,016/- was merely based on presumption and surmises without any tangible material, therefore, in violation of section 45(2) r.w.s. 2 (47)(v). Ultimate addition confirmed was for Rs. 42,34,074/- only, therefore, the addition made was not in conformity with ... Revenue is devoid of merits. 6.1 According to the aforesaid findings of the ITAT, it is explicitly clear that the provisions of section 45(2) r.w.s. 48 for Capital Gain and “Income from Business and Profession” shall apply in the 15 I.T.A. No.173/RPR/2019 CO No. 26/RPR/2019 present case also

Girdharbhai Haribhai Gajera, Surat vs. ITO(International Taxation), Surat

In the result, additional grounds raised by the assessee is allowed

ITA 143/SRT/2019[2015-16]Status: DisposedITAT Surat22 Feb 2023AY 2015-16

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपील सं./Ita No.143/Srt/2019 (िनधा"रणवष" / Assessment Year: (2015-16) (Physical Court Hearing) Girdharbhai Haribhai Gajera Income Tax Officer 1,Vrushal Nagar, Opp. (International Taxation), 107, 1St Vs. Ktargam Police Station, Floor, Anavil Business Centre, Katargam Road, Surat-35004 Adajan-Hazira Road, Opp. Star Bazar, Adajan, Surat-395009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Abepg 7339 M (Assessee ) (Respondent)

For Appellant: Shri Hiren R.Vepari, C.AFor Respondent: Shri Vinod Kumar, Sr-D.R
Section 142(1)Section 143(2)Section 143(3)Section 2(14)Section 271Section 45(2)

time of sale, because, agricultural land is itself converted as stock-in-trade from capital asset. As per provisions of Section 45(2) of the Act when capital asset is converted into stock-in-trade and such stock-in-trade is sold subsequently, assessee is required to compute income

Maddimisetti Srinivasu, Tanuku vs. The Asst . Commissioner of Income Tax, Circle-1, Rajahmundary

In the result, the appeal of the assessee is allowed for statistical purpose

ITA 96/VIZ/2022[2017-2018]Status: DisposedITAT Visakhapatnam31 Jan 2023AY 2017-2018

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Bleआयकर अपील सं./I.T.A.No.96/Viz/2022 (ननधधारण वर्ा / Assessment Year : 2017-18) Maddimsetti Srinivasu Vs. Asst.Commissioner Of D.No.1-77, Peddintlamma Street Income Tax Tanuku Mandal Circle-1 Komaravaram Rajahmundry [Pan : Ctxpm3066Q]

For Appellant: Shri G.V.N.Hari, ARFor Respondent: Shri M.N.Murthy Naik, CIT(DR)
Section 142(1)Section 143(3)Section 263Section 45(2)Section 48Section 54F

Tanuku Revenue Mandal with Registered Survey No.846/2 into stock in trade for sale of developed plots. The Ld.PCIT observed that as per section 45(2) of the Act, the profits or gains arising from the transfer by way of conversion by the owner of a capital asset into ... Ld.PCIT set aside the assessment to the file of the AO to determine the capital gains in accordance with the provisions of section 45(2) of the Act as well as business income of the assessee on sale of plots with reference to the issue of sale of plots during

Asst CIT 11(3)(2), Mumbai vs. Zoeteis India Ltd, Mumbai

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

ITA 3285/MUM/2015[2010-11]Status: DisposedITAT Mumbai28 Dec 2022AY 2010-11
Section 50C

building or both in place of the actual sales consideration, if the stamp duty value is higher than the actual consideration. Similarly, section 45(2), 45(3), 45(4) of the Act provides for adopting fair market value instead of the actual consideration in certain specified scenarios, for the purpose

ACIT, Cuddalore Circle, Cuddalore vs. Sarojini B Nair, Vridhachalam

ITA 314/CHNY/2019[2015-16]Status: DisposedITAT Chennai23 Dec 2022AY 2015-16

Bench: Shri V. Durga Rao, Hon’Ble & Shri G. Manjunatha, Hon’Bleआयकर अपील सं./Ita No.314/Chny/2019 िनधा"रण वष" /Assessment Year: 2015-16 The Asst. Commissioner- V. Smt. Sarojini B. Nair, Of Income Tax, No.1, Salem Road, Cuddalore Circle, Vridhachalam. Cuddalore. [Pan: Aavps 9240 B] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.V.Meenakshi Sundar, CA &For Respondent: Mr. AR.V.Sreenivasan
Section 2(47)Section 43CSection 45(2)Section 47

case and submissions filed regarding the additions made. It is not in dispute that when a land is converted into stock-in-trade, section 45(2) of the IT Act is applicable and accordingly assessee is liable for capital gains. In section 45(2), it is clearly stated that liability ... provisions relating to head Capital Gains are not to be made applicable after conversion of the capital asset into stock-in-trade, section 45(2) itself will become inapplicable. One cannot choose to invoke one section for taxation i.e., 45(2) and exclude another section grating exemption

Assistant Commissioner of Income Tax, Central Circel-2(1), Bangalore vs. Sri Mathikere Ramaiah Seetharam, Bangalore

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 544/BANG/2021[2016-17]Status: DisposedITAT Bangalore07 Nov 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

this regard, it is submitted that there is no such finding in the CIT(A)’s order with respect to applicability of section 45(2) of the Act. The provisions of section 45(2) of the Act are applicable in a case of transfer by way of conversion of capital

Assistant Commissioner of Income Tax, Central Circel-2(1), Bangalore vs. Sri Mathikere Ramaiah Seetharam, Bangalore

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 543/BANG/2021[2015-16]Status: DisposedITAT Bangalore07 Nov 2022AY 2015-16

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

this regard, it is submitted that there is no such finding in the CIT(A)’s order with respect to applicability of section 45(2) of the Act. The provisions of section 45(2) of the Act are applicable in a case of transfer by way of conversion of capital

Assistant Commissioner of Income Tax, Central Circel-2(1), Bangalore vs. Sri Mathikere Ramaiah Seetharam, Bangalore

In the result, the appeals filed by the revenue are dismissed and the COs filed by the assessee are partly allowed for statistical purposes

ITA 542/BANG/2021[2014-15]Status: DisposedITAT Bangalore07 Nov 2022AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Appellant: Shri H. Nagin Khincha &For Respondent: Shri M. Mathivanan, D.R
Section 131Section 132(4)Section 153CSection 45(2)

this regard, it is submitted that there is no such finding in the CIT(A)’s order with respect to applicability of section 45(2) of the Act. The provisions of section 45(2) of the Act are applicable in a case of transfer by way of conversion of capital

M/S. Kwality Biscuits Private Limited, Bangalore vs. Deputy Commissioner of Income Tax, Circle- 11(5), Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 675/BANG/2020[2006-07]Status: DisposedITAT Bangalore17 Oct 2022AY 2006-07

Bench: Shri George George K. & Ms. Padmavathy Sassessment Year : 2006-07

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Smt. Priyadarshini Baseganni, Addl.CIT(DR)(ITAT)
Section 115Section 115JSection 143(3)Section 147Section 148Section 250Section 55(2)

IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH : BANGALORE BEFORE SHRI GEORGE GEORGE K., JUDICIAL MEMBER AND Ms. PADMAVATHY S

Addl CIT RG 7(1), Mumbai vs. Peninsula Land Ltd, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 4136/MUM/2012[2008-09]Status: DisposedITAT Mumbai12 Oct 2022AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, HON'BLE JUDICIAL MEMBER AND SHRI S

Peninsula Land Ltd, Mumbai vs. Addl CIT 7(1), Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 3717/MUM/2012[2008-09]Status: DisposedITAT Mumbai12 Oct 2022AY 2008-09

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI VIKAS AWASTHY, HON'BLE JUDICIAL MEMBER AND SHRI S

Kohinoor Textiles Printing Works, Mumbai vs. Asst CIT WD 22(1), Mumbai

ITA 2836/MUM/2013[203-04]Status: DisposedITAT Mumbai25 Aug 2022

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2003-04 Assessment Year: 2004-05 Assessment Year: 2006-07 M/S. Kohinoor Textiles Asst. Commissioner Of Income Printing Works, Tax, M/S. J.J. Mehra & Co., Ward-22(1), Chartered Accountant, Mumbai Vs. 11 Laxmi Building, 2Nd Floor, Off. Turner Road, Bandra (West), Mumbai – 400 050 Pan: Aaafk2198P (Appellant) (Respondent) Present For: Assessee By : Shri Kiran Kapadia, A.R. Revenue By : Shri Tejinder Pal Singh, D.R. Date Of Hearing : 12 . 07 . 2022 Date Of Pronouncement : 25 . 08 . 2022

For Appellant: Shri Kiran Kapadia, A.RFor Respondent: Shri Tejinder Pal Singh, D.R
Section 2Section 45

returned by AO on this issue. 12. The Ld. CIT(A) has also not determined the issue as to whether capital gain under section 45(2) of the Act on conversion of fixed assets being land into stock in trade computing the business loss of Rs.66,63,600/- for assessment

Kohinoor Textiles Printing Works, Mumbai vs. DCIT WD 22(1), Mumbai

ITA 2514/MUM/2011[2006-07]Status: DisposedITAT Mumbai25 Aug 2022AY 2006-07

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2003-04 Assessment Year: 2004-05 Assessment Year: 2006-07 M/S. Kohinoor Textiles Asst. Commissioner Of Income Printing Works, Tax, M/S. J.J. Mehra & Co., Ward-22(1), Chartered Accountant, Mumbai Vs. 11 Laxmi Building, 2Nd Floor, Off. Turner Road, Bandra (West), Mumbai – 400 050 Pan: Aaafk2198P (Appellant) (Respondent) Present For: Assessee By : Shri Kiran Kapadia, A.R. Revenue By : Shri Tejinder Pal Singh, D.R. Date Of Hearing : 12 . 07 . 2022 Date Of Pronouncement : 25 . 08 . 2022

For Appellant: Shri Kiran Kapadia, A.RFor Respondent: Shri Tejinder Pal Singh, D.R
Section 2Section 45

returned by AO on this issue. 12. The Ld. CIT(A) has also not determined the issue as to whether capital gain under section 45(2) of the Act on conversion of fixed assets being land into stock in trade computing the business loss of Rs.66,63,600/- for assessment

Kohinoor Textile Printing Works, Mumbai vs. DCIT RG 22(1), Navi Mumbai

ITA 3923/MUM/2010[2006-07]Status: DisposedITAT Mumbai25 Aug 2022AY 2006-07

Bench: Shri Kuldip Singh & Shri Gagan Goyalassessment Year: 2003-04 Assessment Year: 2004-05 Assessment Year: 2006-07 M/S. Kohinoor Textiles Asst. Commissioner Of Income Printing Works, Tax, M/S. J.J. Mehra & Co., Ward-22(1), Chartered Accountant, Mumbai Vs. 11 Laxmi Building, 2Nd Floor, Off. Turner Road, Bandra (West), Mumbai – 400 050 Pan: Aaafk2198P (Appellant) (Respondent) Present For: Assessee By : Shri Kiran Kapadia, A.R. Revenue By : Shri Tejinder Pal Singh, D.R. Date Of Hearing : 12 . 07 . 2022 Date Of Pronouncement : 25 . 08 . 2022

For Appellant: Shri Kiran Kapadia, A.RFor Respondent: Shri Tejinder Pal Singh, D.R
Section 2Section 45

returned by AO on this issue. 12. The Ld. CIT(A) has also not determined the issue as to whether capital gain under section 45(2) of the Act on conversion of fixed assets being land into stock in trade computing the business loss of Rs.66,63,600/- for assessment

Addl.C.I.T. RG. 7(1), Mumbai vs. Peninsula Land Ltd., Mumbai

ITA 1479/MUM/2012[2007-08]Status: DisposedITAT Mumbai18 Aug 2022AY 2007-08
For Appellant: Shri Achal SharmaFor Respondent: Shri Vijay Mehta
Section 143(3)

arising on conversion of land into stock-in-trade taxed by the Assessing Officer in the hands of the Assessee in terms of Section 45(2) of the Act. This issue also stands decided in favour of the Assessee by the order of the above said order of the Tribunal

DCIT Cir 7(1), Mumbai vs. Peninsula Land Ltd, Mumbai

ITA 4600/MUM/2009[2006-07]Status: DisposedITAT Mumbai18 Aug 2022AY 2006-07
For Appellant: Shri Achal SharmaFor Respondent: Shri Vijay Mehta
Section 143(3)

arising on conversion of land into stock-in-trade taxed by the Assessing Officer in the hands of the Assessee in terms of Section 45(2) of the Act. This issue also stands decided in favour of the Assessee by the order of the above said order of the Tribunal

ACIT 30(3), Mumbai vs. Suratchandra B. Thakkar -HUF, Mumbai

In the result, all the three appeals of the In the result, all the three appeals of the Revenue are In the result, all the three appeals of the dismissed

ITA 4335/MUM/2018[2008-09]Status: DisposedITAT Mumbai12 Aug 2022AY 2008-09

Bench: Shri Om Prakash Kant () & Shri Sandeep Singh Karhail () Assessment Year: 2006-07 & Assessment Year: 2007-08 & Assessment Year: 2008-09 Acit-30(3), Shri Suratchandra B. Thakkar C-13, 5Th Floor, R. No. 510, (Huf), Pratyaksha Kar Bhavan, Bkc, Vs. Tipco Compound, Rani Sati Bandra (East), Marg, Malad (E), Mumbai-400051. Mumbai-400097. Pan No. Aaaht 0788 G Appellant Respondent Revenue By : Mr. Hoshang B. Irani, Dr Assessee By : None Date Of Hearing : 28/07/2022 Date Of Pronouncement : 12/08/2022

For Appellant: NoneFor Respondent: Mr. Hoshang B. Irani, DR

IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “G” MUMBAI BEFORE SHRI OM PRAKASH KANT (ACCOUNTANT MEMBER) AND SHRI SANDEEP