“beneficial owner”

International TaxDTAADTAA951 judgments

The decision most relied on for beneficial owner is Shyam Sunder v. Ram Kumar, (2001) 8 SCC 24 (para 44); Brij Mohan Das Laxman Das v. CIT (5 SCC 482), cited in 261 judgments on BharatTax.

Leading authorities on beneficial owner

Shyam Sunder v. Ram Kumar, (2001) 8 SCC 24 (para 44); Brij Mohan Das Laxman Das v. CIT

5 SCC 482 · 1997 · Supreme Court

261

citing judgments

For income to be assessable under the head 'Income from House Property' as per Section 22 of the Income Tax Act, 1961, beneficial ownership or the right to enjoy the property is sufficient; legal ownership is not a mandatory prerequisite.

Mysore Minerals Ltd. v. CIT

239 ITR 775 · 1999 · Supreme Court

215

citing judgments

For income tax purposes, the 'owner' of a property is the person who is entitled to receive income in their own right, bears the risks incidental to ownership, and utilizes the asset, even if the sale deed is not formally registered. This beneficial ownership is sufficient for claiming depreciation or capital gains exemption under relevant sections.

CIT v. Ankitech (P) Ltd.

340 ITR 14 · 2012 · High Court

202

citing judgments

Deemed dividend under section 2(22)(e) cannot be taxed in the hands of a non-shareholder. The Supreme Court confirmed this view, affirming the Delhi High Court's decision in Ankitech.

PCIT v. Ambe Tradecorp Pvt. Ltd.

145 Taxmann.com 27 · 2022 · High Court

169

citing judgments

No addition under section 68 can be made for a loan if the assessee furnishes material proving the identity of the loan givers, demonstrates they are not the beneficial owner, and has repaid the loan in a subsequent year.

CIT v. Universal Medicare Pvt. Ltd.

324 ITR 263 · 2010 · High Court

111

citing judgments

Deemed dividend under section 2(22)(e) is assessable only in the hands of the beneficial shareholder who receives the benefit of the loan or advance, and not in the hands of the company receiving the loan.

Miss P. Sarada v. CIT

229 ITR 444 · 1998 · Supreme Court

citing judgments

A loan or advance from a closely held company to a shareholder is a deemed dividend under Section 2(22)(e) upon receipt, unaffected by subsequent repayment or adjustment.

(Refer: CIT v. C.P.Sarathy Mudaliar

83 ITR 170 · 1972 · Supreme Court

citing judgments

For the purpose of deemed dividend under section 2(22)(e) of the Income-tax Act, the term 'shareholder' refers exclusively to a registered shareholder of the company, and not a beneficial owner or non-shareholder.

CIT v. Ravinder Kumar Arora

342 ITR 38 · 2012 · High Court

citing judgments

Deduction under Section 54F cannot be restricted or denied merely because the new residential property, for which the entire consideration is paid by the assessee, is purchased in the joint names of the assessee and their spouse. The assessee is considered the actual and constructive owner of the property.

Judgments citing beneficial owner

ITO 19.2.4, Mumbai vs. Nishita Vijay Mehta, Mumbai

The appeal of the assessee are dismissed

ITA 2989/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Oct 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri. Leyaqat Ali Aafaqui, Sr. Ar

Section 250Section 50ESection 54ESection 54F

given the confirmation letter in which 87 shares were gifted solely to the appellant i.e. Nishita Vijay Mehta, and that she is the sole beneficial owner, was duly accepted by the Income Tax Department and therefore a contrary view cannot be taken to say that the shares were jointly held ... Mehta. However, it is to be noted that Mrs. Kavita Vijay's name was added only for the sake of convenience and the real beneficial owner of the said shares of IMCC, was solely Vijay Tulsidas Mehta. (Copy of the Share Transfer Forms showing transfer of such shares is enclosed

Solvay S A, Mumbai vs. The Deputy Commissioner of Income Tax International Tax Circle 4(2)(2), Mumbai

In the result, the appeal is partly allowed

ITA 2071/MUM/2025[2022-23]Status: DisposedITAT Mumbai27 Oct 2025AY 2022-23

Bench: Shri Saktijit Dey & Shri Narendra Kumar Billaiya

For Respondent: Shri Vijay Mehta

Section 143(3)Section 9(1)(vii)

within such doubtful category. 16. A contention has been raised by the counsel for the Revenue that the recipient of FTS shall be the beneficial owner of fees and if the non-resident entity which ostensibly receives the fee is a mere conduit for the other related companies ... amount received by it is simply made over to those companies, then no benefit can be sought from art.13 of the Treaty. If the beneficial owner is someone other than the immediate recipient of fee, the legal position has to be examined in light of the relevant Treaties governing

Nishita Vijay Mehta, Mumbai vs. Income Tax Officer Ward 19(2)4, Mumbai

The appeal of the assessee are dismissed

ITA 1787/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Oct 2025AY 2017-18

Bench: Shri Amit Shukla, Jm & Ms Padmavathy S, Am

For Respondent: Shri. Leyaqat Ali Aafaqui, Sr. Ar

Section 250Section 50ESection 54ESection 54F

Six Continents Hotels Inc, Gurgaon vs. ACIT, Circle-3(1)(2), International Taxation, New Delhi

In the result, Appeals of the Assessee in ITA No

ITA 1459/DEL/2022[2018-19]Status: DisposedITAT Delhi24 Oct 2025AY 2018-19

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(3)Section 144C(13)

company incorporated and a tax resident of USA. The Assessee is part of the Inter-Continental Hotel Group ('IHG') and was the legal and beneficial owner of the registered trademark of certain IHG brands including 2ITA No. 373& 1459/Del/2021 Six Continents Hotel Inc. Vs. ACIT 'Holiday Inn', 'Holiday Inn Express

Six Continents Hotels Inc., Usa vs. ACIT Circle- 3 (1)(2) - International Taxation, New Delhi

In the result, Appeals of the Assessee in ITA No

ITA 373/DEL/2021[2017-18]Status: DisposedITAT Delhi24 Oct 2025AY 2017-18

Bench: S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(3)Section 144C(13)

Vodafone Idea Ltd. (Earlier Knwon As Vodafone Mobile Services Ltd.), Mumbai vs. ACIT, . Circle-26(2), New Delhi

In the result, all above said grounds are allowed for statistical purpose

ITA 8361/DEL/2019[2012-13]Status: DisposedITAT Delhi24 Oct 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shriyogesh Kumar U.S.Vodafone Idea Ltd Vs. Acit, (Earlier Known As Vodafone Circle-26(2), Mobile Services Ltd) New Delhi 10Th Floor, Birla Centurion, Century Mills Compound, Pandurang Budhkar Marg, Worli, Mumbai, Maharastra (Appellant) (Respondent) Pan: Aaacb2100P

For Appellant: Shri Salil Kapoor, AdvFor Respondent: Shri S. K,. Jadav, CIT DR

Section 115JSection 143(3)Section 144C(5)Section 92C

INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “H”: NEW DELHI BEFORE SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER AND SHRIYOGESH KUMAR U.S

Spandana Sphoorty Financial Limited, Hyderabad vs. ACIT., Circle 3(2), Hyderabad

ITA 821/HYD/2025[2017-18]Status: DisposedITAT Hyderabad17 Oct 2025AY 2017-18

Section 143(3)Section 145Section 69A

आयकर अपीलीय न्यायाधिकरण में, हैदराबाद 'B' बेंच, हैदराबाद IN THE INCOME TAX APPELLATE TRIBUNAL Hyderabad ‘B’ Bench, Hyderabad श्री रवीश

Yogesh Chander & Sons HUF, Ludhiana vs. Income Tax Officer, Ward 5(1), Ludhiana

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

ITA 625/CHANDI/2025[2022-23]Status: DisposedITAT Chandigarh16 Oct 2025AY 2022-23

Bench: the Ld. CIT(A). Ld. CIT(A) confirmed the action of the CPC holding that the appellant had not fulfilled the conditions of the proviso to Rule 37BA(2) of the Income Tax Rules, 1962, namely (i) filing of declaration with the deductor, and (ii) reporting of tax deduction by the deductor in the name of the other person.

For Appellant: Shri Sumit Kumar Bansal, C.AFor Respondent: Dr. Ranjit Kaur, Add. CIT, Sr. DR

Section 143(1)Section 199Section 250

Karta in his individual capacity. 2. That the Ld. Additional / JCIT Appeal-2 Noida, has failed to appreciate that the assessee is the “beneficial owner” of shares of M/s Hero Moto Corp Ltd. (formerly known as Hero Honda Motors Ltd.) for last more than three decades and dividend declared ... Yogesh Chander Munjal (Individual), being the deductee, requesting the company to report the corresponding TDS in the name of Yogesh Chander & Sons (HUF), the beneficial owner of 32,500 shares. 6.1 The learned AR drew our attention to the letter dated 14.10.2025, filed before the Tribunal, enclosing the following:  Annexure

Ramsamy Pongianna Gounder Desamani, Pallipalayam vs. Itd, Ward 2, Tiruchengode

ITA 2438/CHNY/2024[2011-12]Status: DisposedITAT Chennai16 Oct 2025AY 2011-12

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunathaआयकर अपील सं./Ita No.:2438/Chny/2024 निर्धारण वर्ष / Assessment Year: 2011-12 Late. Ramasamy Pongianna Gounder Desamani, (Represented By Legal Heir Shri. P.D.Balachandhran) 79, R.P.Street, Sankari Bye-Pass Road, R.P.Street,\Pallipalayam – 638 006. [Pan:Acqpd-3208-H] (अपीलार्थी/Appellant) Ito, Vs. Ward -2, Tiruchengode. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/Appellant By प्रत्यर्थी की ओर से/Respondent By : Shri. T. S. Lakshmi Venkataraman, F.C.A. : Ms. Gauthami Manivasagam, J.C.I.T. सुनवाई की तारीख/Date Of Hearing घोषणा की तारीख/Date Of Pronouncement : 09.09.2025 : 16.10.2025 आदेश /Order Per S. R. Raghunatha, Am: This Appeal Filed By The Assessee Is Directed Against The Order Passed By The Learned Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre (Nfac), Delhi, [Herein After “Ld. Cit(A)] Dated 16.07.2024 & Pertains To Assessment Year 2011-12. :-2-:

For Respondent: Shri. T. S. Lakshmi Venkataraman, F.C.A

Section 139Section 147Section 148Section 151Section 2(22)(e)Section 250

आयकर अपीलीय अधिकरण, 'बी' न्यायपीठ, चेन्नई IN THE INCOME TAX APPELLATE TRIBUNAL 'B' BENCH, CHENNAI श्री एस एस विश्वनेत्र रवि

M/S. Bekaert Industries Private Limited, Pune vs. Deputy Commissioner of Income Tax, Pune

The appeal of the assessee is allowed

ITA 1003/PUN/2017[2012-13]Status: DisposedITAT Pune14 Oct 2025AY 2012-13

Bench: Dr.Manish Borad & Shri Vinay Bhamore

Section 143(3)Section 40Section 9(1)(vi)

services may also be taxed in the Contracting State in which they arise and according to the laws of that State, but if the beneficial owner of the royalties or fees for technical services is a resident of the other Contracting State, the tax so charged shall not exceed

Haryana Building and Other Construction Workers Welfare Board, Panchkula vs. DCIT, Exemption, Chandigarh

In the result, this appeal of the Assessee stands dismissed

ITA 337/CHANDI/2023[2016-17]Status: DisposedITAT Chandigarh10 Oct 2025AY 2016-17

Bench: Shri Laliet Kumar & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 237/Chd/2020 निर्धारण वर्ष / Assessment Year : 2014-15 Haryana Building & Other Construction Workers Welfare Board, Bays No. 29- 30, Sector 4, Panchkula, Haryana The Dcit, बनाम Circle 2, Vs. Exemption, Chandigarh स्थायी लेखा सं./ Pan No: Aaath6995H अपीलार्थी/Appellant प्रत्यर्थी/Respondent आयकर अपील सं./ Ita Nos.337 To 339/Chd/2023 निर्धारण वर्ष / Assessment Years : 2016-17, 2017-18 & 2018-19 Haryana Building & Other Construction Workers Welfare Board, Bays No. 29- 30, Sector 4, Panchkula, Haryana The Dcit बनाम Exemption, Vs. Chandigarh स्थायी लेखा सं./ Pan No: Aaath6995H अपीलार्थी/Appellant प्रत्यर्थी/Respondent आयकर अपील सं./ Ita No. 63/Chd/2021 निर्धारण वर्ष / Assessment Year : 2015-16 Haryana Building & Other Construction Workers Welfare Board, Bays No. 29-30, Sector 4, Panchkula, Haryana The Dcit बनाम Exemptions, Vs. Chandigarh स्थायी लेखा सं./ Pan No: Aaath6995H अपीलार्थी/Appellant प्रत्यर्थी/Respondent ( Physical Hearing ) निर्धारिती की ओर से/Assessee By : Sh. Nikhil Goyal, Advocate, Sh. Ashok Goyal, Ca & Sh. Sifatfreet Singh, Ca राजस्व की ओर से/ Revenue By : Sh. Manav Bansal, Cit Dr सुनवाई की तारीख/Date Of Hearing 08.12.2025 उदघोषणा की तारीख/Date Of Pronouncement 10.12.2025 आदेश/Order Per Bench: The Captioned Appeals Preferred By The Assessee Are Directed Against The Separate Orders Of The Ld. Commissioner Of Income- Tax (Appeals) For Different Assessment Years, As Per The Details Given Below: S.No.

For Appellant: Sh. Nikhil Goyal, AdvocateFor Respondent: Sh. Manav Bansal, CIT DR

Section 263

आयकर अपीलीय अधिकरण, चण्डीगढ़ न्यायपीठ, चण्डीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL CHANDIGARH BENCH, ‘A’, CHANDIGARH BEFORE SHRI LALIET KUMAR

DCIT, Central Circle - 4(4), Kolkata vs. M/S. Evernewcommodeal Pvt. Ltd., Kolkata

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

ITA 1536/KOL/2025[2019-20]Status: DisposedITAT Kolkata10 Oct 2025AY 2019-20

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubeyita Nos.1535 & 1536/Kol/2025 Assessment Years: 2018-19 & 2019-20 Dcit, Central Circle-4(4), Kolkata.…………………………….…….……Appellant Vs. M/S Evernewcommodeal Pvt. Ltd..……………….………...……...…..…..Respondent 11, Pollock Street, Kol- 1. [Pan: Aabce9293P] Appearances By: Shri Altaf Hossain, Addl. Cit-Dr, Appeared On Behalf Of The Appellant. Shri Manish Tiwari, Fca, Appeared On Behalf Of The Respondent. Date Of Concluding The Hearing : September 17, 2025 Date Of Pronouncing The Order : October 10, 2025 Order Per Pradip Kumar Choubey: Both The Captioned Appeals Have Been Preferred By The Assessee For The Assessment Years 2018-19 & 2019-20 Against Separate Orders Both Dated 25.04.2025 Of The Commissioner Of Income Tax (Appeals)-27, Kolkata [Hereinafter Referred To As ‘Cit(A)’] Passed U/S 250 Of The Income Tax Act (Hereinafter Referred To As The ‘Act’) Respectively. Since, The Issues Involved In Both The Appeals Are Common & Relate To The Same Assessee, Therefore, These Appeals Have Been Heard Together & Are Being Disposed Of By This Consolidated Order. Ita No.1535/Kol/2025 Is Taken As Lead Case For Narration Of Facts. Ita No.1535/Kol/2025 - Brief Facts Of The Case Are That U/S 2. 139(1) Of The Act On 10-10-2019 Declaring A Total Income At Rs. 10,02,960/-. The Same Was Processed U/S 143(1) Of The Act. Later, A Search & Seizure Operation U/S 132 Of The Act Was Conducted At "Ladhuram Toshniwal Group" On 08-03-2022 As A Part Of "Jain Group" Of Concerns/ Persons At Various Places & Simultaneously, Business

Section 127Section 132Section 133ASection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2Section 250

case of normal business and repaid the said loan through banking channel in the next FY, the assessee cannot be said to be beneficial owner of the money without any cogent evidence brought by the AO on record and addition under section 68 by the AO cannot be sustained. Additionally

DCIT, Central Circle - 4(4), Kolkata vs. M/S. Evernewcommodeal Pvt. Ltd., Kolkata

In the result, ITA No.1535/Kol/2025 of the revenue is dismissed

ITA 1535/KOL/2025[2018-19]Status: DisposedITAT Kolkata10 Oct 2025AY 2018-19

Section 127Section 132Section 133ASection 142(1)Section 143(1)Section 143(2)Section 147Section 148Section 2Section 250

Ramesh Jaisinghani, Mumbai vs. Deputy Commissioner of Income Tax Central Circle -5(2), Mumbai

In the result, appeal of the assessee is allowed

ITA 980/MUM/2025[2020-21]Status: DisposedITAT Mumbai10 Oct 2025AY 2020-21

Bench: SHRI AMIT SHUKLA (Judicial Member), SHRI GIRISH AGRAWAL (Accountant Member)

Section 143(3)Section 244ASection 50(2)(ec)Section 55(2)(aa)Section 55(2)(ac)Section 55(2)(as)Section 56(2)(ac)

IN THE INCOME TAX APPELLATE TRIBUNAL, ‘D’ BENCH MUMBAI BEFORE: SHRI AMIT SHUKLA, JUDICIAL MEMBER & SHRI GIRISH AGRAWAL, ACCOUNTANT MEMBER

Prakash Katariya, Pune vs. Income Tax Officer Ward 11(1), Pune

In the result, the appeal filed by the assessee is allowed for statistical purposes

ITA 1830/PUN/2025[2020-21]Status: DisposedITAT Pune07 Oct 2025AY 2020-21

Bench: Shri R. K. Pandaassessment Year : 2020-21

For Appellant: Shri Sudin SabnisFor Respondent: Ms. Sailee Dhole, JCIT

Section 143(2)Section 36

facts and circumstances of the case, the CIT(A) has erred in not appreciating the submission of the Appellant that he was the beneficial owner of the loan availed and the interest paid was in substance wholly and exclusively utilised for the purpose of business activities of the Appellant under

ITO, Ward 6(1), Ludhiana vs. M/S Jujhar Construction & Travels Pvt. Ltd., Ludhiana

In the result, appeal of the Revenue is dismissed

ITA 536/CHANDI/2022[2013-14]Status: DisposedITAT Chandigarh06 Oct 2025AY 2013-14

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 536/Chd/2022 "नधा"रण वष" / Assessment Year: 2013-14 The Ito, Vs M/S Jujhar Construction & Ward 6(1), Travels Pvt. Ltd.,Near Pull Jawaddi, Ludhiana. Pakhowal Road, Ludhiana. "थायी लेखा सं./Pan No: Aabcj1127H अपीलाथ"/Appellant ""यथ"/Respondent Assessee By : Shri Sudhir Sehgal, Advocate Revenue By : Shri Manav Bansal, Cit, Dr Date Of Hearing : 02.09.2025 Date Of Pronouncement : 06.10.2025 Physical Hearing O R D E R Per Raj Pal Yadav, Vp

For Appellant: Shri Sudhir Sehgal, AdvocateFor Respondent: Shri Manav Bansal, CIT, DR

Section 143(2)Section 2(22)(e)

which the public are substantially interested, of any sum by way of advance or loan to a shareholder, being a person who is the beneficial owner of shares (not being shares entitled to a fixed rate of dividend whether with or without a right to participate in profits holding ... otherwise) made after the 31st day of May, 1987, by way of advance or loan to a shareholder, being a person who is the beneficial owner of shares (not being shares 8 of 801 entitled to a fixed rate of dividend whether with or without a right to participate

Kabir Mulchandani, Mumbai vs. ACIT (OSD-II) Cr 7, Mumbai

In the result, appeal of the assessee is allowed

ITA 5342/MUM/2024[2000-2001]Status: DisposedITAT Mumbai06 Oct 2025AY 2000-2001

Bench: Shri Anikesh Banerjee & Smt. Renu Jauhriआयकरअपीलसं./Itano.5342/Mum/2024 (िनधा"रणवष" / Assessment Year: 2000-01) Kabirmulchandani V/S. Acit (Osd-Ii) Cr-7, बनाम C/O R.C Kapoor & Co, Mumbai Chartered Accountants Acit (Osd-Ii) Cr-7, Mumbai D-36, South Extension Part-Ii, New Delhi 110049 "थायी लेखा सं./जीआइआर सं./Pan/Gir No: Aabpm1224B Appellant/अपीलाथ" Respondent/"ितवादी ..

For Appellant: Shri Sanjeev Kapoor, CAFor Respondent: Shri. Hemanshu Joshi, SR DR

Section 142(1)Section 144Section 2(22)(e)Section 250Section 68Section 69C

आयकरअपीलीय"ायािधकरण"ायपीठ, मुंबई| IN THE INCOME-TAX APPELLATE TRIBUNAL “E” BENCH, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER & SMT

Deepak Parekh, Usa vs. Deputy Director of Income Tax CPC, Bengaluru

Appeal is allowed for statistical purpose

ITA 126/IND/2025[2022-23]Status: DisposedITAT Indore30 Sept 2025AY 2022-23

Bench: Shri B.M. Biyani

Section 143(1)

both the assessee and his wife. . Since thé residential apartment appeared as asset in the books of the appellant and he was the sole beneficial owner of the property, he offered the entire sale proceeds and claimed the entire capital loss of Rs. 11,80,710/- and entire ... deducted in the hands of the wife of the appellant, are as under: 1. The assessee is the sole beneficial owner of the impugned residential apartment no. B-1203, Wing-B, 12th Floor, Cedar Block, Greenage, Bangalore as : i) The payment for purchase of this property on 28.09.2017 for Rs.1

Ashutosh Kumar Verma, Lakhimpur Kheri vs. ACIT, Sitapur

The appeal of the assessee stands allowed

ITA 115/LKW/2024[2016-17]Status: DisposedITAT Lucknow30 Sept 2025AY 2016-17

Bench: Shri. Sudhanshu Srivastava & Shri Nikhil Choudharyassessment Year: 2016-17 Ashutosh Kumar Verma V. The Acit Atkonwa, Lakhimpur Kheri Sitapur - New Uttar Pradesh Tan/Pan:Adqpv4727J (Appellant) (Respondent) Appellant By: Shri P. K. Kapoor, C.A. Respondent By: Shri R. K. Agarwal, Cit(Dr) O R D E R

For Appellant: Shri P. K. Kapoor, C.AFor Respondent: Shri R. K. Agarwal, CIT(DR)

Section 131(1)(d)Section 133(6)

said account was fraudulently opened by someone in the name of the assessee in collusion with the bank authorities and the "appellant" is neither beneficial owner of the said bank account nor has benefitted from the credit entry of Rs.6,12,04,962/- appearing in the said bank account

Income Tax Officer, Piramal Chambers - Income Tax Office, Mumbai, Maharashtra vs. Go Go Garments, Mumbai

ITA 4483/MUM/2024[2013-14]Status: DisposedITAT Mumbai30 Sept 2025AY 2013-14

Bench: Justice (Retd.) C V Bhadang & Ms Padmavathy S, Am

For Appellant: Shri Swapnil Choudhary, Sr. DRFor Respondent: Shri Gunjan Kakkad, AR

Section 250Section 50C

action of Ld. CIT(A) to delete the addition of Rs. 6,80,11,020/- made u/s. 50C holding that assessee was not beneficial owner without considering the facts that the Registered Sale Deed dated 21.05.2012 for sale of three commercial galas has been signed by the Mr. Vinodkumar Goenka ... action of Ld. CIT(A) to delete the addition of Rs. 6,80,11,020/- made u/s. 50C holding that assessee was not beneficial owner without considering the fact that the assessee firm had sold three commercial galas as per the Registered Deed dated 21.05.2012 giving its name