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“joint development agreement”

Capital GainsSection 45(5A)Section 45(5A)386 judgments

The decision most relied on for joint development agreement is CIT v. Balbir Singh Maini (398 ITR 531), cited in 228 judgments on BharatTax.

Leading authorities on joint development agreement

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.

Chaturbhuj Dwarkadas Kapadia v. CIT
260 ITR 491 · 2003 · High Court
150
citing judgments

For capital gains purposes, a 'transfer' under section 2(47)(v) occurs and capital gains arise in the year when possession of the property is handed over in part performance of a contract, such as a joint development agreement. This was the settled position before the specific provisions of section 45(5A) were introduced.

CIT v. T.K. Dayalu
202 Taxmann 531 · 2011 · High Court
58
citing judgments

In a Joint Development Agreement (JDA), capital gains arise for chargeability to tax when the complete control over the property is passed to the developer, with the date of such transfer of control being relevant for determining the assessment year. This includes considerations of possession under Section 53A of the Transfer of Property Act.

CIT v. V.R. Karpagam
373 ITR 127 · 2015 · High Court
40
citing judgments

The principles for exemption under Section 54 of the Income-tax Act apply equally to Section 54F, allowing exemption for multiple residential units received under a joint development agreement if the assessment year is prior to the Finance (No. 2) Act, 2014 amendment.

Potla Nageswara Rao v. DCIT
365 ITR 249 · 2014 · High Court
35
citing judgments

Handing over possession of property under a Development Agreement-cum-GPA in exchange for built-up area constitutes a transfer of a capital asset, triggering capital gains tax, as it satisfies the conditions under Section 2(47)(v) read with Section 53A of the Transfer of Property Act.

Seshasayee Steels (P.) Ltd. v. CIT
421 ITR 46 · 2020 · Supreme Court
33
citing judgments

Handing over possession under a Joint Development Agreement (JDA) does not constitute a 'transfer' under Section 2(47)(v) of the Income Tax Act, 1961, read with Section 53A of the Transfer of Property Act.

CIT v. Dr. T. K. Dayalu
14 Taxmann.com 120 · 2011 · High Court
32
citing judgments

Capital gains arise at the time of execution of a Joint Development Agreement (JDA) and handing over of possession of property to the developer, due to the concept of part performance.

Seshasayee Steels (P.) Ltd. v. Asstt. CIT
115 Taxmann.com 5 · 2020 · Supreme Court
23
citing judgments

Granting a license to a developer for property development does not constitute 'allowing possession' under section 53A of the Transfer of Property Act, and therefore section 2(47)(v) of the Income Tax Act is not attracted.

Judgments citing joint development agreement

Shatrughan K. Patil, Thakurli vs. Asst.Comm.Income Tax Officer Central Circle 2, Thane

ITA 964/MUM/2025[2012-13]Status: DisposedITAT Mumbai17 Feb 2026AY 2012-13

Bench: Smt Beena Pillai & Shri Girish Agrawalassessment Year: 2012-13

For Appellant: Shri Amit Jhaveri and Shri Dharmil Jhaveri, CAsFor Respondent: Shri Arun Kanti Datta, CIT DR
Section 132Section 139(1)Section 143(3)Section 153ASection 2(47)(v)

records of the property card where assessee along with his family stayed and occupied a part of the same. In view of the joint development agreement, Minaxi Developers proceeded to develop the land in two phases, dividing the land equally into two parts, admeasuring 1920 sq. metres each. One building ... facts, assessee claims that he is occupying the said flat only as an alternate accommodation provided by the developer in view of the joint development agreement and does not have ownership, title, rights in the said flat, so provided by the developer. There is no transfer of ownership

M/S. Buhari Hotels & Motels Pvt. Ltd., Chennai vs. DCIT, Corporate Circle-1(2), Chennai

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

ITA 2449/CHNY/2025[2011-12]Status: DisposedITAT Chennai13 Feb 2026AY 2011-12

Bench: Shri George George K & Shri Inturi Rama Raoआयकर अपील सं./Ita No.: 2449/Chny/2025 िनधा"रण वष"/Assessment Year: 2011-12 Buhari Hotels & Motels Pvt. The Deputy Commissioner Ltd., Vs. Of Income Tax, No.6, Gandhi Irwin Road, Corporate Circe 1(2), Egmore, Chennai. Chennai – 600 008. Pan: Aaecb 4681M (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/Appellant By : Ms. Sujaya, Ca ""यथ" क" ओर से/Respondent By : Ms. Gouthami Manivasagam, Addl.Cit सुनवाई क" तारीख/Date Of Hearing : 12.02.2026 घोषणा क" तारीख/Date Of Pronouncement : 13.02.2026

For Appellant: Ms. Sujaya, CAFor Respondent: Ms. Gouthami Manivasagam
Section 250

Brief facts of the case are as follows: The assessee is a company. It had entered into a Joint Development Agreement (JDA) with Chaitanya Developers Pvt., Ltd., on 16.08.2007. As per the terms of the JDA, the developer (Chaitanya Developers :- 3 -: Pvt., Ltd.,) would develop its land

Kesavan Vanithamani, Chennai vs. ITO, Ncw-19(4), Chennai

ITA 2451/CHNY/2025[2017-18]Status: DisposedITAT Chennai10 Feb 2026AY 2017-18

Bench: Ms. Padmavathy.S & Shri Manu Kumar Giriआयकर अपील सं./Ita Nos.2451 & 2452/Chny/2025 िनधा$रण वष$ /Assessment Years: 2017-18 & 2018-19

For Appellant: Mr. R. Sivaraman, AdvocateFor Respondent: Ms. Gouthami Manivasagam, Addl. CIT
Section 250Section 54F

counsel for the assessee. 5. We have heard the parties, and perused the material available on record. The assessee has entered into a joint development agreement and as part of the agreement transferred 52% of the undivided share of land to the developer. The assessee as per agreement

Ashwitha Reddy Baddam, Nizamabad vs. Income Tax Officer, Ward-2, Nizamabad

ITA 1066/HYD/2025[2015-16]Status: DisposedITAT Hyderabad06 Feb 2026AY 2015-16

executed on 15.07.2013 between the assessee, her father, Sri Gaddam Mohan Reddy, younger minor sister, Gaddam Mounika Reddy and the Developer. As per Joint Development Agreement, the parties have agreed to share the developed property in the ratio of 33.10:66.90. The assessee and his co-owners have ... receipt of super built up area. In response, the assessee submitted that the appellant has computed long term capital gains, in pursuant to Joint Development Agreement in the F.Y.2012-13, relevant to A.Y.2013- 14, where the appellant has estimated the sale consideration of Rs.700/- per SFT for super built up area

Mohan Reddy Gaddam, Nizamabad vs. Income Tax Officer, Ward-2, Nizamabad

ITA 1065/HYD/2025[2017-18]Status: DisposedITAT Hyderabad06 Feb 2026AY 2017-18

executed on 15.07.2013 between the assessee, her father, Sri Gaddam Mohan Reddy, younger minor sister, Gaddam Mounika Reddy and the Developer. As per Joint Development Agreement, the parties have agreed to share the developed property in the ratio of 33.10:66.90. The assessee and his co-owners have ... receipt of super built up area. In response, the assessee submitted that the appellant has computed long term capital gains, in pursuant to Joint Development Agreement in the F.Y.2012-13, relevant to A.Y.2013- 14, where the appellant has estimated the sale consideration of Rs.700/- per SFT for super built up area

Gaddam Mohan Reddy, Nizamabad vs. Income Tax Officer, Ward-2, Nizamabad

ITA 1064/HYD/2025[2016-17]Status: DisposedITAT Hyderabad06 Feb 2026AY 2016-17

executed on 15.07.2013 between the assessee, her father, Sri Gaddam Mohan Reddy, younger minor sister, Gaddam Mounika Reddy and the Developer. As per Joint Development Agreement, the parties have agreed to share the developed property in the ratio of 33.10:66.90. The assessee and his co-owners have ... receipt of super built up area. In response, the assessee submitted that the appellant has computed long term capital gains, in pursuant to Joint Development Agreement in the F.Y.2012-13, relevant to A.Y.2013- 14, where the appellant has estimated the sale consideration of Rs.700/- per SFT for super built up area

Gaddam Mohan Reddy, Nizamabad vs. Income Tax Officer, Ward-2, Nizamabad

ITA 1063/HYD/2025[2015-16]Status: DisposedITAT Hyderabad06 Feb 2026AY 2015-16

executed on 15.07.2013 between the assessee, her father, Sri Gaddam Mohan Reddy, younger minor sister, Gaddam Mounika Reddy and the Developer. As per Joint Development Agreement, the parties have agreed to share the developed property in the ratio of 33.10:66.90. The assessee and his co-owners have ... receipt of super built up area. In response, the assessee submitted that the appellant has computed long term capital gains, in pursuant to Joint Development Agreement in the F.Y.2012-13, relevant to A.Y.2013- 14, where the appellant has estimated the sale consideration of Rs.700/- per SFT for super built up area

Nirman Realtors and Developers Limited, Mumbai vs. Circle 2(3)(1), Mumbai

ITA 3447/MUM/2025[2012-13]Status: DisposedITAT Mumbai22 Jan 2026AY 2012-13

Bench: Shri Om Prakash Kant () & Shri Rahul Chaudhary ()

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

This reversal was necessitated by the cancellation of bookings from three buyers owing to delays and other issues related to the joint development agreement entered into by the appellant with the joint developer, Effile Properties Private Limited. To support this claim, the appellant submitted copies of the ledger accounts

Skyline Developers, Pune vs. The Income Tax Officer, Ward4(50, Pune

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

ITA 709/PUN/2023[2006-07]Status: DisposedITAT Pune20 Jan 2026AY 2006-07

Bench: Dr.Manish Borad & Shri Vinay Bhamoreआयकर अपील सं. / Ita No.709/Pun/2023 Assessment Year : 2006-07

For Appellant: Shri Pramod S. ShingteFor Respondent: Shri Amit Bobde
Section 143Section 143(3)Section 147Section 148Section 250Section 80I

commenced and only a Joint Venture Agreement was entered. However, the assessee grossly erred in treating the stamp duty valuation mentioned in the Joint Development Agreement at ₹11,33,80,800 as Revenue for the year and was 7 Skyline Developers erroneously shown as income on Receipt side of profit ... members and, in lieu thereof, secured the right to develop a building project on the balance land 3. Subsequently, Skyline entered into a Joint Development Agreement (JDA) with Brahma Builders ("Brahma") on 21/03/2006. The JDA stipulated a profit-sharing ratio of 32% for Skyline and 68% for Brahma from

Sahodhar Reddy Muddasani, Hyderabad vs. DCIT, Central Circle-1(3), Hyderabad

In the result, appeal of the assessee is allowed

ITA 1619/HYD/2025[2016-17]Status: DisposedITAT Hyderabad15 Jan 2026AY 2016-17

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Madhusudan Sawdiaआ.अपी.सं /Ita No.1619/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2016-17) Shri Sahodhar Reddy Vs. Dy.Cit Muddasani Central Circle 1(3) Hyderabad Hyderabad Pan:Aelpm9122N (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Ca Shri C Maheshwar Reddy राज" व "ारा/Revenue By: Shri Sankar Pandi P, Sr. Dr सुनवाई की तारीख/Date Of Hearing: 06/01/2026 घोषणा की तारीख/Pronouncement: 16/01/2026 आदेश/Order Per Madhusudan Sawdia, A.M.: This Appeal Is Filed By Shri Sahodhar Reddy Muddasani (“The Assessee”), Feeling Aggrieved By The Order Passed By The Learned Commissioner Of Income Tax (Appeals)-12, Hyderabad (“Ld. Cit(A)”) Dated 24.09.2025 For The A.Y. 2016-17. 2. The Assessee Has Raised The Following Grounds Of Appeal:

For Appellant: CA Shri C Maheshwar ReddyFor Respondent: Shri Sankar Pandi P, Sr. DR
Section 132Section 153ASection 2(47)Section 2(47)(v)Section 45(1)Section 53A

assessee, along with Shri Cheruku Anand Reddy and Shri Manohar Reddy Cheruku (hereinafter collectively referred to as “the landowners”), had entered into a Joint Development Agreement (“JDA”) dated 19.01.2016 with the developer. As per the terms of the JDA, in respect of land measuring 676 sq. yards, the landowners were

ACIT, Chennai vs. M/S. Bsr Builders Engineers Contractors, Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1561/CHNY/2025[2016]Status: DisposedITAT Chennai14 Jan 2026

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

assessee that Section 43CB read with ICDS-III as notified u/s 145 of the Act is applicable only to construction contracts and not joint development agreements. The Ld. ITA Nos.1274, 1311, 1312 & 1561/Chny/2025 CO Nos.39 & 47/Chny/2025 (AYs 2016-17 & 2017-18) BSR Builders Engineers Contractors :: 36 :: AR explained that

Bsr Builders Engineers Contractors, Chennai vs. DCIT, Central Circle-2(3), Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1312/CHNY/2025[2017-18]Status: DisposedITAT Chennai14 Jan 2026AY 2017-18

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

assessee that Section 43CB read with ICDS-III as notified u/s 145 of the Act is applicable only to construction contracts and not joint development agreements. The Ld. ITA Nos.1274, 1311, 1312 & 1561/Chny/2025 CO Nos.39 & 47/Chny/2025 (AYs 2016-17 & 2017-18) BSR Builders Engineers Contractors :: 36 :: AR explained that

Bsr Builders Engineers Contractors, Chennai vs. DCIT, Cent. Circle-2(3), Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1311/CHNY/2025[2016-17]Status: DisposedITAT Chennai14 Jan 2026AY 2016-17

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

assessee that Section 43CB read with ICDS-III as notified u/s 145 of the Act is applicable only to construction contracts and not joint development agreements. The Ld. ITA Nos.1274, 1311, 1312 & 1561/Chny/2025 CO Nos.39 & 47/Chny/2025 (AYs 2016-17 & 2017-18) BSR Builders Engineers Contractors :: 36 :: AR explained that

DCIT, Chennai vs. Bsr Builders Engineers Contractors, Chennai

In the result, the appeal of the assessee for AYs 2016-17 & 2017-18

ITA 1274/CHNY/2025[2017]Status: DisposedITAT Chennai14 Jan 2026

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita Nos.1311 & 1312/Chny/2025 िनधा"रणवष"/Assessment Years: 2016-17 & 2017-18 V. Bsr Builders Engineers Contractors, The Dcit, No.28, Bsr Janus, Tank Bund Road, Central Circle-2(3), Nungambakkam, Chennai-600 034. Chennai. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent) आयकर अपील सं./Ita Nos.1274 & 1561/Chny/2025 िनधा"रणवष"/Assessment Years: 2017-18 & 2016-17 V. The Dcit / Acit, Bsr Builders Engineers Central Circle-2(3), Contractors, Chennai. No.28, Bsr Janus, Tank Bund Road, Nungambakkam, Chennai-600 034. [Pan: Aagfb 7140 N] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr.G. Baskar, Advocate &For Respondent: Mr.Nishanth Rao, JCIT

assessee that Section 43CB read with ICDS-III as notified u/s 145 of the Act is applicable only to construction contracts and not joint development agreements. The Ld. ITA Nos.1274, 1311, 1312 & 1561/Chny/2025 CO Nos.39 & 47/Chny/2025 (AYs 2016-17 & 2017-18) BSR Builders Engineers Contractors :: 36 :: AR explained that

Syken Suresh Mehta, Mumbai vs. ITO Ward 19(3)(1), Mumbai

ITA 6771/MUM/2025[2022-23]Status: DisposedITAT Mumbai14 Jan 2026AY 2022-23

Bench: Shri Saktijit Dey & Shri Jagadishsuken Suresh Mehta, Income Tax Officer, A-28, Sterling Apartments, 19(3)(1), 38, Peddar Road, Mumbai Cumballa Hills, Vs. Mumbai- 400026

For Appellant: Shri Vijay Mehta, CA And Shri Tarang Mehta, AdvocateFor Respondent: Shri Anil Kanti Datta, CIT-DR
Section 48

assessee acquired 18,443 sq.ft. of land in Coimbatore through registered sale deed dated 28.08.1981. On 21.08.2013, the assessee entered into a Joint Development Agreement (JDA) cum Memorandum of Understanding (MOU) with Elysium Properties India Pvt. Ltd. for jointly developing a property named ‘Elysium The Address’. As per the terms

Adnan Rahmat, Kolkata vs. ITO, Ward 30(1), Kolkata

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

ITA 674/KOL/2025[2013-2014]Status: DisposedITAT Kolkata13 Jan 2026AY 2013-2014

Bench: Shri George Mathanआयकर अपील सं/Ita No.674/Kol/2025 (नििाारण वर्ा / Assessment Year :2013-2014) Adnan Rahmat, Vs Ito Ward-30(1), Kolkata C/O Subash Agarwal & Associates, Advocates, Siddha Gibson, 1, Gibson Lane, Suite 213, 2Nd Floor, Kolkata-700069 Pan No. :Adepr 1602 G (अपीलार्थी /Appellant) .. (प्रत्यर्थी / Respondent) नििााररती की ओर से /Assessee By : Shri Subash Agarwal, Advocate राजस्व की ओर से /Revenue By : Shri Abhijit Adhikary, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 13/01/2026 घोषणा की तारीख/Date Of Pronouncement : 13/01/2026 आदेश / O R D E R This Is An Appeal Filed By The Assessee Against The Order Dated 07.03.2025, Passed By The Ld.Cit(A), National Faceless Appeal Centre (Nfac), Delhi, For The Assessment Year 2013-2014. 2. It Was Submitted By The Ld.Ar That The Reasons As Mentioned By The Ao In Page 1 Of The Assessment Order Did Not Having Live Link To The Actual Issue, Insofar As This Was The Case Of Joint Development Agreement & No Income Could Be Assessed In The Hands Of The Assessee On The Basis Of Such Joint Development Agreement Until The Completion Of The Development Of The Project. 3. At This Point, It Was Requested To The Ld. Ar To Provide The Reasons Recorded. It Was Submitted That The Revenue Has Not Provided The Same. 4. Ld. Sr. Dr Also Submitted That He Does Not Have Immediately Copy Of The Reasons Recorded.

For Appellant: Shri Subash Agarwal, AdvocateFor Respondent: Shri Abhijit Adhikary, Sr. DR

page 1 of the assessment order did not having live link to the actual issue, insofar as this was the case of joint development agreement and no income could be assessed in the hands of the assessee on the basis of such joint development agreement until the completion

Acid, Circle-5(1), Kolkata vs. Emami Realty Limited, Kolkata

ITA 1457/KOL/2024[2021-22]Status: DisposedITAT Kolkata12 Jan 2026AY 2021-22

Bench: Shri Rajesh Kumar & Shri Pradip Kumar Choubey

Section 143(3)Section 194ISection 2Section 250Section 50CSection 56Section 56(2)Section 56(2)(x)

inter alia, involved in real estate project titled 'Emami City' in Jessore Road, Kolkata, for which the assessee has entered into a Joint Development Agreement with Oriental Sales Agencies (India) Pvt Ltd [in short ‘OSAIPL'], a private limited company which was also inter alia, involved in the business of real

Raj Kumar Singh, Patna vs. ITO, Ward-6(4), Patna

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

ITA 341/PAT/2025[2016-17]Status: DisposedITAT Patna30 Dec 2025AY 2016-17

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133(6)Section 144Section 250

action of the AO in treating the amount of Rs 2,45,00,250/- as suspiciously making addition on the basis of Joint Development Agreement. The assessment is erroneous, illegal, and unsupported by evidence. 4. For that the Hon'ble CIT (A) has erred in not allowing proper opportunity

ACIT., Circle-5(1), Hyderabad vs. Madineni Sitaramaiah, Hyderabad

In the result, the appeal filed by the Revenue is allowed, and the cross- objection filed by the assessee is dismissed

ITA 598/HYD/2025[2018-19]Status: DisposedITAT Hyderabad24 Dec 2025AY 2018-19

Bench: Us:

Section 143(3)Section 2(22)(e)

utilized the same in his proprietorship business by his own admission. Also, the assessee could not furnish any documents viz. joint development agreement with the said company in respect of financial year 2017-18. There was not a shred of evidence furnished by the assessee to demonstrate business relationship between

ACIT Central Circle 1(4) Mumbai, Mumbai vs. Kalyanee Fortune Constructions, Mumbai

In the result, all the above appeals in ITA Nos

ITA 5779/MUM/2024[2019-20]Status: DisposedITAT Mumbai23 Dec 2025AY 2019-20

Bench: Shri Narender Kumar Choudhry & Shri Prabhash Shankar

For Appellant: Shri Neelkanth Khandelwal, ARFor Respondent: Ms. Kavitha Kaushik, (Sr. DR)
Section 131Section 132(1)Section 133ASection 143(3)

assessee and GHL were having profit sharing ration of 44.64% and 55.36% respectively in the said project. Since the assessee was in joint development agreement of the property “Ganga Acropolis”, proportionate addition was made in its hands also. During the course of survey proceedings, certain jottings, loose papers and whatsup ... assessee’s share in the alleged cash receipts found during survey proceedings on GHL, the assessee and GHL had entered into Joint Development Agreement for development of the land owned by assessee at P a g e | 6 ITA No. 4444, 4445, 4448 & 5779/Mum/2024