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“date of transfer”

Capital GainsSection 2(47)Section 2(47)965 judgments

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

Leading authorities on date of transfer

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.

Sanjeev Lal v. CIT
365 ITR 389 · 2014 · Supreme Court
122
citing judgments

For claiming capital gains exemption under beneficial provisions like section 54, the 'date of transfer' can be the date of the agreement to sell, particularly when coupled with substantial advance consideration or an enforceable right, adopting a purposive and liberal interpretation to acknowledge the assessee's intent.

Suraj Lamp & Industries (P) Ltd. v. State of Haryana
340 ITR 1 · 2012 · Supreme Court
64
citing judgments

A transfer of immovable property by way of sale is legally valid only through a duly stamped and registered deed of conveyance. Unregistered instruments like agreements to sell, General Power of Attorney, or wills do not transfer title or create an interest in the property.

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.

PCIT v. Swananda Properties (P.) Ltd.
111 Taxmann.com 94 · 2019 · High Court
50
citing judgments

Prior to the incorporation of the proviso to section 43CA(1) with effect from 1st April 2019, section 43CA did not envisage any limit regarding the difference between the stamp duty value and the actual sale consideration received by the assessee for the transfer of immovable property that was stock-in-trade.

CIT v. Ashaland Corporation
133 ITR 55 · 1982 · High Court
44
citing judgments

Income from the sale of immovable property, including any 'on-money' component, is taxable only when the sale is complete, marked by the execution and registration of the sale deed and/or transfer of possession to the buyer.

CIT v. R.L. Sood
245 ITR 727 · 2000 · High Court
42
citing judgments

Exemption under Section 54 for capital gains on a residential property is available even if the sale deed is not registered within the stipulated time, provided a substantial amount of consideration is paid, or the delay in completion/registration is beyond the assessee's control.

Judgments citing date of transfer

Asirvad Micro Finance Limited, Anna Salai vs. Assistant Commissioner of Income Tax, Corporate Circle -1(1), Chennai

In the result, the appeal of the assessee is allowed

ITA 1140/CHNY/2025[2016-17]Status: DisposedITAT Chennai05 Dec 2025AY 2016-17

Bench: Shri Aby T Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.1140/Chny/2025 Assessment Years: 2016-17 Asirvad Micro Finance Limited, Assistant Commissioner Of No.9, 9Th Floor, Club House Road, Income Tax, Annasalai, Corporate Circle-1(1), Chennai-600 002 Chennai. [Pan: Aagca5275J] (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Assessee By : Mr.P.R.Prasanna Varma, Fca & Mr.Arjun Rajagopalan, C.A. प्रत्यर्थी की ओर से /Revenue By : Mr.Bipin C.N, Cit सुनवाई की तारीख/Date Of Hearing : 25.09.2025 घोषणा की तारीख /Date Of Pronouncement : 05.12.2025 आदेश / O R D E R Per Amitabh Shukla, A.M :

For Appellant: Mr.P.R.Prasanna Varma, FCA &For Respondent: Mr.Bipin C.N, CIT
Section 2(18)Section 2(71)Section 56(2)Section 56(2)(viib)Section 8

public limited company in which public were substantially interested. Thus, as the assessee company was a deemed public limited company on the date of transfer of shares, provisions of section 56(2)(viib) would not apply it its case. There cannot therefore be any case for making any addition

DCIT(TDS)-2(3), Mumbai vs. Novartis Healthcare Private Limited, Mumbai

Appeal is allowed

ITA 2768/MUM/2025[2020-21]Status: DisposedITAT Mumbai05 Dec 2025AY 2020-21

Bench: Shri Pawan Singh (Jm) & Shri Omkareshwar Chidara (Am) Dcit(Tds)-2(3) Novartis Healthcare Private 320, 3Rd Floor, Cumbala Hill, Limited Mtnl Te Bldg. Peddar Road Vs. 7Th Floor, Inspire Bkc, G Gopalrao Deshmukh Marg Block, Bkc Main Road Mumbai-400 026. Bandra, Mumbai-400 051. Appellant Respondent C.O. No. 121/Mum/2025 (Assessment Year : 2020-21)

For Respondent: S/Shri Anish Thacker (CA)
Section 133ASection 192Section 194Section 194HSection 201

stage of mere grant. b) Section 17(2)(vi) of the Act and the Explanation says that on the date of transfer or allotment, the difference between FMV of option on the date of option exercised and price paid by employee is liable to tax in the hands of employee

Amit Kumar Verma, Patna vs. ITO, Ward- 6(1), Patna

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

ITA 357/PAT/2023[2015-16]Status: DisposedITAT Patna04 Dec 2025AY 2015-16

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 144Section 147Section 148Section 234ASection 250Section 271(1)(c)

Appeal), National Faceless Appeal Centre (NFAC). Delhi, has erred in confirming the date of registration of the conveyance deed as the date of transfer of the property to the developer. 5. For that the CIT (Appeal), National Faceless Appeal Centre (NFAC), Delhi erred in passing order by not following principle ... developer to deal with the property, the date of the contract/JDA viz., 18 August 1994 would be the relevant date to decide the date of transfer under Section 2(47)(v) and, in which event, the question of substantial performance of the contract thereafter did not arise. 6.7 The Bangalore

Bhagwat Prasad Malviya, Bhopal vs. ITO-3(1), Bhopal

The appeal of the assessee is allowed for statistical

ITA 456/IND/2025[2014-15]Status: HeardITAT Indore04 Dec 2025AY 2014-15

Bench: Shri Bhagirath Mal Biyani & Shri Paresh M Joshiassessment Year: 2014-15 Bhagwat Prasad Malviya Ito -3(1) 28, Crp Phatak Road Bhopal बनाम/ Bairagarh, Vs. Bhopal (Assessee/Appellant) (Revenue/Respondent) Pan: Afbpm8998M Assessee By Shri N.D. Patwa, Ar Revenue By Shri Ashish Porwal, Sr. Dr Date Of Hearing 02.12.2025 Date Of Pronouncement 04.12.2025

Section 143(3)Section 154Section 246ASection 250Section 253Section 548Section 54B

purchased before the date of sale (15.07.2013 vs sale on 07.09.2013), violating the condition under section 548 that purchase must be after the date of transfer. An amount of Rs. 1,53,57,901 claimed under Capital Gains Account Scheme was deposited in an ordinary FD account, in the name ... within the permitted time window post-sale (07.09.2013). The land purchased on 15.07.2013 for Rs. 7,79,754 was prior to the date of transfer, hence ineligible under section 548. There is no nexus provided by the appellant that land purchased earlier was in anticipation of transaction under consideration

Renu Anandani, Jabalpur vs. NFAC, Delhi

In the result, the appeal is allowed for statistical purposes

ITA 120/JAB/2023[2012-13]Status: DisposedITAT Jabalpur28 Nov 2025AY 2012-13

Bench: SH. KUL BHARAT, VICE PRESIDENT AND SH. NIKHIL CHOUDHARY (Accountant Member)

For Appellant: Sh. Neeraj Agarwal, C.AFor Respondent: Sh. Alok Bhura, Sr. DR
Section 143(3)Section 147Section 263

when there is no contrary evidence available with him that payment has been made for such investment.AO had considered market rate on the date of transfer to Demat account from physical form and considered it as unexplained investment. Findings as ultimately recorded by AO had been based more on presumptions ... evidence available with him that any payment has been made for such investment. The AO had considered the market rate on the date of transfer to the demat account from physical form and considered it as unexplained investment. This finding was based more on presumption rather than of cogent proof

Dilip Dhirajlal Shah, Mumbai vs. ITO Ward 24(1)(1), Mumbai

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

ITA 5168/MUM/2025[2017-18]Status: DisposedITAT Mumbai27 Nov 2025AY 2017-18

Bench: Smt Beena Pillai & Smt.Renu Jauhri7 (A.Y.2017-18)

For Appellant: Shri Bharat Kumar RajpurohitFor Respondent: Shri Annavaran Kosuri- Sr. AR
Section 147Section 2(47)Section 250Section 56Section 56(2)Section 56(2)(vii)

agreed for sale in the FY 2009-10, the registration of the property was made in the F.Y. 2016-17. Therefore, the date of transfer of property to be considered from the date of registration i.e. in the F.Y. 2016- 17. Hence, the applicability of the section

Gattula Lakshmi Madhavi, Visakhapatnam vs. Assistant Commissioner of Income Tax, Central Circle-1, Visakhapatnam

The appeal of the assessee is allowed for statistical purposes in terms of our aforesaid observations

ITA 384/VIZ/2025[2015-16]Status: DisposedITAT Visakhapatnam26 Nov 2025AY 2015-16

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.384/Viz/2025 (िनधा"रण वष"/Assessment Year:2015-16) Gattula Lakshmi Madhavi Vs. Assistant Commissioner Visakhapatnam. Of Income Tax, Central Circle-1, Pan: Agfpg8929H Visakhapatnam. (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Gvn Hari, Advocate (Hybrid Hearing) राज" व "ारा/Revenue By: Dr. Aparna Villuri, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 15/10/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 28/02/2025, Which In Turn Arises From The Order Passed By The Assessing Officer (For Short, “Ao”) Under Section 144 R.W.S 147 Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 16/03/2022 For The Assessment Year 2015-16. The Assessee Has Assailed The Impugned Order On The Following Grounds Of Appeal Before Us:

For Appellant: Shri GVN Hari, AdvocateFor Respondent: Dr. Aparna Villuri, Sr. AR
Section 133ASection 142(1)Section 144Section 148Section 56(2)Section 56(2)(vii)

that the value adopted by the stamp valuation authority, i.e., SRO valuation exceeded the market value of the property as on the date of transfer had failed to refer the matter to the Valuation Cell, therefore, the very basis for adoption of the stamp value (SRO valuation) is fallacious. Accordingly

Dodla Dairy Limited, Hyderabad vs. DCIT Circle -8(1), Hyderabad

ITA 466/HYD/2022[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Us:

For Appellant: Shri Aashik Shah, C.AFor Respondent: Ms. U. Mini Chandran
Section 143(3)Section 144Section 80Section 801BSection 80J

transfer as recorded in the accounts of the eligible business does not correspond to the market value of such goods as on the date of transfer, then for the purposes of deduction u/ss. 80IB or 80IA of the Act, the profits and gains of the eligible 18 ITA TP 466/Hyd/2022 ... consideration for such transfer recorded in the books of account does not correspond to the market value of such goods as on the date of transfer, then for the purpose of computing deduction u/s 80IB(11A) of the Act, the relevant profits from the eligible business shall be computed

Sigma Paradise, Ghaziabad vs. DCIT, Ward 2(2)(1), Ghaziabad

The appeal is allowed

ITA 823/DEL/2024[2013-14]Status: DisposedITAT Delhi26 Nov 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Year: 2013-14 Sigma Paradise, Vs Dcit, Km-78, Kavi Nagar, Ward 2(2)(1), Ghaziabad, Ghaziabad. Uttar Pradesh – 201 002. Pan:Aazfs9643L (Appellants) (Respondents) Assessee By : Shri Rajiv Khandelwal, Ca; & Shri Gagan R. Khandelwal & Shri Jaind Kumar Jaiswal, Advocates Revenue By : Shri Manish Gupta, Sr. Dr Date Of Hearing : 18.09.2025 Date Of Pronouncement : 26.11.2025

For Appellant: Shri Rajiv Khandelwal, CA; &For Respondent: Shri Manish Gupta, Sr. DR
Section 11Section 143(3)Section 147Section 148Section 4Section 50CSection 6

valuation authority under the Stamp Act is excessive and does not correspond with the fair market value of the property as on the date of transfer and that a reference be made for fresh valuation. In the instant case, no such recourse appears to have been taken by the appellant

Poonam Dhananjay Sandu, Navi Mumbai vs. Income Tax Officer, Navi Mumbai

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

ITA 2050/MUM/2025[2017-18]Status: DisposedITAT Mumbai25 Nov 2025AY 2017-18

Bench: Shri Sandeep Gosain, () & Shri Girish Agrawal, ()

Section 143(3)Section 234BSection 250Section 270A(3)Section 270A(9)Section 54

Ground No. 1: Denial of Deduction Under Section 54 Our Submissions:- Proposition 1 :- Agreement for Sale dt. 01.12.2016 is to be construed as date of Transfer as right in personam has been created in favour of the purchaser and hence section 54 is to be allowed :- 5. Under Section ... extinguishing rights in a capital asset. 7. Before lower authorities, it has been erroneously adopted the date of registration (30.03.2017) as the date of transfer, ignoring the fact that the Agreement for Sale dated 01.12.2016, supported by substantial advance of Rs. 2.47 crs and 5 Poonam Dhananjay Sandu, Mumbai. enforceability

Kusum Sahgal, Gurugram vs. ACIT, Circle-19(2), Delhi

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

ITA 341/DEL/2025[2016-17]Status: DisposedITAT Delhi21 Nov 2025AY 2016-17

Bench: Shri S Rifaur Rahman & Shri Vimal Kumarassessment Year: 2016-17 Kusum Sahgal, Through Lr Shri Vs. Acit, Circle-19(2), Viney Sagar Sahgal, New Delhi Mg-2002, The Magnolias, Golf Course Road Dlf Phase-V, Gurugram, 122 002 Haryana Pan :Aatps3766J (Appellant) (Respondent)

Section 133(6)Section 142(1)Section 143(2)Section 250Section 54BSection 54ESection 54F

Madras High Court). 7. Learned Authorized Representative for the Department submitted that the assessee jointly owns more than one residential property on the date of transfer of residential assets, such as joint ownership consequentially fall within the majority of provisions of proviso to section ... gains arising from transfer of a long-term capital asset other than a residential house. However, it has been observed that, on the date of transfer of the original asset, the assessee was jointly owning more than one residential property and relied upon the statutory framework as under: “II. Statutory

M/S Estin Tie Up Pvt. Ltd., Kolkata vs. A.C.I.T., Central Circle-1(2), Kolkata

In the result, the two cross appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

ITA 32/KOL/2020[2013-14]Status: DisposedITAT Kolkata20 Nov 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy & Shri Rakesh Mishra

Section 143(3)Section 50C(1)Section 55A

found to be tenable on the facts mentioned in the assessment order and since the contention was not tenable, the first date of transfer was treated as transfer as a whole and the market value as determined on revaluation was treated as the deemed consideration. Hence, ₹90 Crore ... crore and not Rs.1.65 crore.” 14. During the course of hearing before us, the issues to be decided were (i) What is the date of transfer and (ii) What is the sale consideration so as to compute the capital gains in the relevant A.Y. The Ld. AR vehemently argued that

A.C.I.T., Central Circle-1(2), Kolkata vs. M/S Estin Tie Up Pvt. Ltd., Kolkata

In the result, the two cross appeals filed by the assessee as well as the Revenue are partly allowed for statistical purposes

ITA 141/KOL/2020[2013-14]Status: DisposedITAT Kolkata20 Nov 2025AY 2013-14

Bench: Shri Duvvuru Rl Reddy & Shri Rakesh Mishra

Section 143(3)Section 50C(1)Section 55A

found to be tenable on the facts mentioned in the assessment order and since the contention was not tenable, the first date of transfer was treated as transfer as a whole and the market value as determined on revaluation was treated as the deemed consideration. Hence, ₹90 Crore ... crore and not Rs.1.65 crore.” 14. During the course of hearing before us, the issues to be decided were (i) What is the date of transfer and (ii) What is the sale consideration so as to compute the capital gains in the relevant A.Y. The Ld. AR vehemently argued that

Assistant Commissioner of Income Tax, Central Circle-2, Trichy vs. Ramasamy Rajasehar, Perambalur

In the result, appeal filed by the Revenue is dismissed and the Cross-Objection filed by the assessee is partly allowed

ITA 3336/CHNY/2024[2014-15]Status: DisposedITAT Chennai20 Nov 2025AY 2014-15

Bench: Shri S.S. Viswanethra Ravi & Shri S. R. Raghunatha

For Appellant: Shri. D. Anand, AdvocateFor Respondent: Mr. Shiva Srinivas, C.I.T
Section 143(3)Section 69

conclusion of the Assessing Officer in assessment for assessment year 2001-02 is that he refers to the assessee's submission regarding the date of transfer being on 12-4-2000 when the broker raised the bill dated 12-4-2000 after scheduled pay in/pay-out of securities to Stock Exchange

Lalmuni Devi, Patna vs. ITO, Patna

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

ITA 18/PAT/2025[2013-14]Status: DisposedITAT Patna18 Nov 2025AY 2013-14

Bench: Shri Sonjoy Sarma & Shri Rakesh Mishra

Section 133(6)Section 144Section 147Section 148Section 234ASection 234BSection 250Section 48Section 50CSection 55

physical possession is handed over later. It is noted that the registration of the land development agreement in FY 2012-13 established the date of transfer for tax purposes, and the valuation under Section 50C of the Income Tax Act should be applied based on this registered date. In view

Point Mani Janaki, Chennai vs. ITO, Ward-2(1), Tirupur

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

ITA 2306/CHNY/2025[2016-17]Status: FixedITAT Chennai14 Nov 2025AY 2016-17

Bench: Shri S.S. Viswanethra Ravi & Shri Amitabh Shuklaआयकर अपील सं./I.T.A. No.2306/Chny/2025 िनधा"रण वष"/Assessment Year: 2016-17 Point Mani Janaki, Vs. The Income Tax Officer, W/O Point Mani, Ward 2(1), Door No. 6/32 A3, Point Illam, North Tiruppur. Street, Vijayapuram Post, Nallur, Tiruppur 641 606. [Pan:Agdpj8781C] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : None ""थ" की ओर से/Respondent By : Shri R.V. Aroon Prasad, Addl. Cit सुनवाई की तारीख/ Date Of Hearing : 13.11.2025 घोषणा की तारीख /Date Of Pronouncement : 14.11.2025 आदेश /O R D E R Per S.S. Viswanethra Ravi: This Appeal Filed By The Assessee Is Directed Against The Order Dated 16.07.2025 Passed By The Ld. Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre [Nfac], Delhi For The Assessment Year 2016-17. 2. When The Appeal Was Taken Up For Hearing, None Appeared On Behalf Of The Assessee Nor Filed Any Adjournment Petition. Hence, We Proceed To Decide The Appeal On Merits After Hearing The Ld. Dr.

For Appellant: NoneFor Respondent: Shri R.V. Aroon Prasad, Addl. CIT
Section 133(6)Section 54Section 54F

Tirupur Municipal Corporation issued a letter stating that there are seven residential houses were under the ownership of the assessee as on the date of transfer of original capital assets. He drew our attention to the letter issued by Triupur Municipal Corporation, which is in vernacular language and translated ... inspector to obtained field inquiries as mentioned in para 20 and 21 of the assessment order, given a factual finding that as on date of transfer of the long-term asset, the assessee owned more than one residential properties. Therefore, the assessee has violated the provisions of section 54F, proviso

ACIT, Circle 28(1), New Delhi, Delhi vs. Shalini Garg, Delhi

In the result, the appeal of the Revenue is dismissed

ITA 1767/DEL/2025[2022-23]Status: DisposedITAT Delhi14 Nov 2025AY 2022-23

Bench: Shri Mahavir Singh & Shri Krinwant Sahay

For Appellant: Shri Jaspal Singh, CAFor Respondent: Shri Manish Gupta, Senior DR
Section 143(3)Section 144BSection 54

note that the appellant has transferred the original asset on 07.02.2022 accordingly the time period available for construction is three years from the date of transfer of original asset i.e. upto 06.02.2025. Thus, denying exemption by the Assessing Officer as order vide no.ITBA/AST/S/143(3)/2023-24/1062096661(1) dated 06.03.2024 stating that completing certificate ... against the law. Since the statute has given the clear time period of three year, for construction of new asset, from the date of transfer of original asset, denying exemption almost one year before the period on the ground that construction was not completed is absolutely unwarranted and blatant disregard

Anil Pannalal Jain, Mumbai vs. Income Tax Officer, Kautilya Bhavan, Mumbai

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

ITA 4663/MUM/2025[2018-19]Status: DisposedITAT Mumbai13 Nov 2025AY 2018-19

Bench: Shri Sandeep Gosain

Section 17Section 250Section 53ASection 56(2)(x)

established through various judicial pronouncements: 1. Registration Requirement: Section 53A of the Transfer of Property Act requires registration for enforceability M 2. Transfer Date: Legal transfer of immovable property occurs only upon registration 3. The Sujauddin case directly supports the Revenue's position vii. Alternative Arguments: arguments: 7 Anil Pannalal ... Payment Through Banking Channels: While payments were made through proper banking channels, this does not alter the legal position regarding the date of transfer 3. Section 56(2)(x) Applicability: The assessee argues that section 56(2)(x) was not applicable in AY 201314. This argument is misconceived because

Daulat Singh Haldea, Jaipur vs. ITO WD 3(3), Jaipur

The appeal is partly allowed as regards

ITA 1366/JPR/2025[2012-13]Status: DisposedITAT Jaipur11 Nov 2025AY 2012-13

Bench: SHRIGAGAN GOYAL (Accountant Member), SHRI NARINDER KUMAR (Judicial Member)

For Appellant: Shri Dilip Shivpuri, AdvFor Respondent: Shri Gaurav Awasthi, JCIT
Section 143Section 143(3)Section 271(1)(c)Section 54ESection 80C

this sub-section shall apply where— (a) the assessee,— (i) owns more than one residential house, other than the new asset, on the date of transfer of the original asset; or (ii) purchases any residential house, other than the new asset, within a period of one year after the date ... original asset; or (iii) constructs any residential house, other than the new asset, within a period of three years after the date of transfer of the original asset; and 10 Daulat Singh Haldea, Jaipur. (b) the income from such residential house, other than the one residential house owned

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

आयकर अपीलीय अिधकरण,च"ीगढ़ "ायपीठ “ए” , च"ीगढ़ IN THE INCOME TAX APPELLATE TRIBUNAL, CHANDIGARH BENCH “A”, CHANDIGARH HEARING