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26 results for “transfer pricing”+ Section 54Fclear

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Key Topics

Section 54F32Section 5425Capital Gains20Long Term Capital Gains13Deduction13Section 143(3)12Addition to Income12Exemption10Section 2639

BASHEER NOORULLAH KHAN,BANGALORE vs. COMMISSIONER OF INCOME TAX (APPEALS), BANGALORE

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

ITA 575/BANG/2019[2013-14]Status: DisposedITAT Bangalore31 Jul 2019AY 2013-14

Bench: Shri Arun Kumar Garodia & Shri Pavan Kumar Gadaleassessment Year : 2013-14 Shri Basheer Noorullah Khan, No. 116B, 5Th Block, Khb The Commissioner Of Colony, Koramangala, Vs. Income Tax (Appeals), Bangalore – 560 034. Bangalore. Pan: Ajxpk3037H Appellant Respondent Assessee By : Shri B.S. Balachandran, Advocate Revenue By : Dr. P.V. Pradeep Kumar, Addl. Cit (Dr) Date Of Hearing : 11.07.2019 Date Of Pronouncement : 31.07.2019

For Appellant: Shri B.S. Balachandran, AdvocateFor Respondent: Dr. P.V. Pradeep Kumar, Addl. CIT (DR)
Section 17ASection 53ASection 54Section 54F

price by Page 6 of 9 payment in kind or adjustment towards a debt or for other monetary consideration. The Hon’ble Delhi High Court has also considered another judgment of Hon’ble Apex Court rendered in the case of CIT Vs. Podar Cement Pvt. Ltd. as reported in [1997] 226 ITR 625. In section 54F also, the same term

Showing 1–20 of 26 · Page 1 of 2

Section 1328
Section 45(2)8
Section 1486

MR. PRAKASH CHAND BETHALA,BANGALORE vs. THE DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE - 7(1), BANGALORE

ITA 999/BANG/2019[2007-08]Status: DisposedITAT Bangalore28 Jan 2021AY 2007-08

Bench: Shri Chandra Poojari & Shri George George K.Assessment Year: 2007-08

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Shri Kannan Narayanan, Jt.CIT(DR)(ITAT), Bengaluru
Section 148Section 234Section 50C

price paid or promised or part paid and part promise. Sale how made – Such transfer, in the case of tangible immoveable property of the value of one hundred rupees and upwards, or in the case of a reversion or other intangible thing, can be made only by a registered instrument. In the case of tangible immoveable property of a value

ACIT, BANGALORE vs. SHRI. PRASHANTH PRAKASH, BANGALORE

In the result, the appeal by the Revenue is dismissed, while the Cross Objection by assessee is treated as allowed for statistical purposes

ITA 864/BANG/2014[2009-10]Status: DisposedITAT Bangalore11 Jun 2015AY 2009-10

Bench: Shri N.V. Vasudevan & Shri Abraham P. Georgeassessment Year : 2009-10

For Appellant: Shri H.N. Khincha, CAFor Respondent: Shri P. Dhivahar, Jt. CIT(DR)
Section 143(3)Section 54F

54F of the Act to the assessee. 11. For the reasons given above, we do not find any merits in this appeal by the Revenue and the same is dismissed. CO 86/Bang/2015 12. As far as cross objection by the assessee is concerned, the grounds of appeal read as follows:- “2. On the facts and circumstances of the case

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 6(3)(1), BANGALORE vs. SRI. SANDEEP BHUJANGA SHETTY, BANGALORE

In the result, appeal filed by assessee stands allowed as indicated above and appeal filed by revenue stands dismissed

ITA 1068/BANG/2019[2015-16]Status: DisposedITAT Bangalore06 Mar 2020AY 2015-16

Bench: Shri. B. R. Baskaran & Smt. Beena Pillai

For Appellant: Shri. Manjeet Singh, Addl. CIT – DRFor Respondent: Shri. S. Ramasubramanian, C A
Section 54Section 54F

transfer of original asset, in lieu of Circular No. 667 dated 18/10/1993 issued by CBDT. Aggrieved by order of Ld. CIT(A), both revenue as well as assessee are in appeal before us now. Assessee raised following Additional Grounds: 1 That the learned Commissioner of Income-Tax (Appeals) erred in law and on facts in not considering the total cost

HANCHIPURA CHANNAIAH NANDAKISHORE,MAHALKSHMIPURAM vs. INCOME TAX OFFICER WARD INTL, TAXATION 1(2) BANGALORE, BANGALORE

In the result appeal filed by the assessee is allowed

ITA 258/BANG/2025[2018-19]Status: DisposedITAT Bangalore04 Nov 2025AY 2018-19

Bench: Shri Prashant Maharishi & Shri Keshav Dubeyit(It)A No.258/Bang/2025 Assessment Year : 2018-19 Hanchipura Channaiah Nandakishore 87, 2Nd Stage & Phase Mahalakshmipuram 2Nd Stage, 14Th Main, West Of Chord Ito Road Vs. Ward International Taxation 1(2) Mahalakshmipuram Bangalore Bangalore 560 086 Pan No :Blrpn0428A Appellant Respondent Appellant By : Sri Siddesh N Gaddi, A.R. Respondent By : Dr. Divya K.J., D.R. Date Of Hearing : 07.08.2025 Date Of Pronouncement : 04.11.2025

For Appellant: Sri Siddesh N Gaddi, A.RFor Respondent: Dr. Divya K.J., D.R
Section 139(1)Section 142(1)Section 147Section 148Section 148ASection 54Section 54(2)Section 80T

54F or section 54G or section 54GA or section 54GB were inserted by the Finance Act, 2019 which is effective from 01.04.2020, but the impugned case on hand is related to the AY 2018-19 & therefore the exemption u/s 54/54F can be claimed even without filling a return of income. Lastly the ld. AR submitted that the Assessee has invested

MRS.KAVITA TIWARI,BANGALORE vs. INCOME TAX OFFICER, BANGALORE

In the result, the assessee’s appeal for asst

ITA 1916/BANG/2016[2011-12]Status: DisposedITAT Bangalore11 Oct 2017AY 2011-12

Bench: Shri Sunil Kumar Yadav & Shri Jason P Boazmrs. Kavita Tiwari, D-202, Adarsh Residency, 8Th Block, Jayanagar, Sangam Circle, Bengaluru. . Appellant Vs. The Income-Tax Officer, Ward-4(4), Bengaluru. . Respondent Pan – Acvpt1583G. Appellant By : Shri R.E Balasubramaniam, C.A Respondent By : Shri M.K Biju, Jcit Date Of Hearing : 16-08-2017 Date Of Pronouncement : -10-2017 O R D E R

For Appellant: Shri R.E Balasubramaniam, C.AFor Respondent: Shri M.K Biju, JCIT
Section 143(1)Section 143(3)Section 54

price of the new property to be Rs.68,46,050/- as reflected in the purchased deed dated ITA No.1916/B/16 5 14/10/2010 and after disallowing certain other items of expenses, reworked the net LTCG at Rs.1,06,33,176/- after allowing exemption of Rs.44,77,234/- u/s 54 of the Act to the extent of 50% of the amount invested

INCOME TAX OFFICER, WARD- 1(2)(2), BANGALORE vs. SHRI MUJEEB URRAHMAN, BANGALORE

In the result, the appeal by the revenue is partly allowed

ITA 1523/BANG/2019[2014-15]Status: DisposedITAT Bangalore31 Aug 2021AY 2014-15

Bench: Shri Chandra Poojari & Smt. Beena Pillaiassessment Year : 2014-15

For Appellant: Shri V. Srinivasan, AdvocateFor Respondent: Smt. H. Kabila, Addl.CIT (DR)(ITAT), Bengaluru
Section 54

price paid for the land was more than the long-term capital gains in the hands of the assessee on sale of her capital asset. But the assessee could not construct the proposed residential house in the land purchased by her as proposed due to an injunction order from the civil court. Even though these circumstances were explained before

DCIT, BANGALORE vs. SHRI. NARAYAN MANDYAM VEERABUDHI, BANGALORE

In the result, the appeal of the revenue is dismissed

ITA 1248/BANG/2016[2010-11]Status: DisposedITAT Bangalore29 Jan 2020AY 2010-11

Bench: Shri B.R Baskaran & Smt. Beena Pillaiassessment Year : 2010-11

For Appellant: Shri V Srinivasan, AdvocateFor Respondent: Shri Manjeet Singh, Addl. CIT (DR
Section 2(14)Section 2(47)Section 54F

54F of the Act. The Revenue is aggrieved by the decision so rendered by ld CIT(A). 5. We heard the parties and perused the record. We noticed that the assessee has relied on various case laws before ld CIT(A) and the first appellate decided the issue in favour of the assessee by considering those case laws

DR. DEVIKA GUNASHEELA,BANGALORE vs. JCIT, BANGALORE

ITA 1047/BANG/2016[2012-13]Status: DisposedITAT Bangalore26 Aug 2020AY 2012-13

Bench: Shri N.V. Vasudevan & Shri A.K. Garodiaassessment Year: 2012-13

For Appellant: Shri Narendra Sharma, A.RFor Respondent: Shri S. Sundar Rajan, D.R
Section 45Section 48Section 54Section 54F

54F, 54G and 5 Dr. Devika Gunasheela, Bengaluru Page 4 of 19 4H, be chargeable to income-tax under the head "Capital gains", and shall be deemed to be the income of the previous year in which the transfer took place. Under Section 48 of the Act, income chargeable under the head "Capital gains" shall be computed, by deducting from

M/S. SASKEN TECHNOLOGIES LIMITED,BANGALORE vs. JOINT COMMISSIONER OF INCOME TAX, SPECIAL RANGE - 6, BANGALORE

In the result, appeal of the assessee is partly allowed

ITA 2546/BANG/2019[2016-17]Status: DisposedITAT Bangalore18 Mar 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri B. R. Baskaranassessment Year : 2016-17 M/S. Sasken Technologies Limited, Vs. Jcit, No.139/25, Ring Road, Domlur, Special Range – 6, Bengaluru-560071. Bengaluru. Pan : Aaecs 6424 R Appellant Respondent Appellant By : Shri. Padam Chand Khincha, Ca Respondent By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru. Date Of Hearing : 09.03.2022 Date Of Pronouncement : 16.03.2022 O R D E R Per N.V. Vasudevanthis Is An Appeal By The Assessee Against The Order Dated 27.11.2019 Of Cit(A), Bengaluru -10, Relating To Assessment Year 2016-17. 2. Ground No.1 Raised By The Assessee Is General & Calls For No Specific Adjudication. Grounds Nos.2 & 3 Raised By The Assessee Is With Regard To The Issue Whether The Gain On Sale / Assignment Of Intellectual Property Rights (Ipr) Is Assessable To Tax At All & If So Assessable To Tax Whether It Has To Be Assessed To Tax Under The Head “Income From Business Or Profession” Or “Capital Gain”. Page 2 Of 31

For Appellant: Shri. Padam Chand Khincha, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 1

54F, 54G and 54H, be chargeable to income-tax under the head "Capital gains", and shall be deemed to be the income of the previous year in which the transfer took place. Income chargeable under the head capital gain accrues to an Assessee the moment, an Assessee effects transfer of a capital Asset. Sec.2(14) of the Income

ARJUN M RANGA,MYSURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL), BENGALURU

In the result, the appeal of the assessee is dismissed

ITA 692/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Feb 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143Section 263Section 54FSection 57

transfer of the capital asset, which is a settled position of law. It can be done from any source and the deduction claimed u/s. 54F of the Act is allowable. Hence, the Pr. CIT has rightly observed in the impugned order that there was no adverse inference sought to be made with regard to the eligibility to claim deduction

ANIRUDH MURTHY RANGA,MYSURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL), BENGALURU

In the result, both the appeals of the assessees are dismissed

ITA 676/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Feb 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143Section 263Section 54FSection 57

transfer of the capital asset, which is a settled position of law. It can be done from any source and the deduction claimed u/s. 54F of the Act is allowable. Hence, the Pr. CIT has rightly observed in the impugned order that there was no adverse inference sought to be made with regard to the eligibility to claim deduction

GURU PAVAN RANGA,MYSURU vs. PRINCIPAL COMMISSIONER OF INCOME TAX, (CENTRAL), BANGALORE

In the result, both the appeals of the assessees are dismissed

ITA 677/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Feb 2022AY 2016-17

Bench: Shri Chandra Poojari & Smt. Beena Pillai

For Respondent: Shri Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru
Section 143Section 263Section 54FSection 57

transfer of the capital asset, which is a settled position of law. It can be done from any source and the deduction claimed u/s. 54F of the Act is allowable. Hence, the Pr. CIT has rightly observed in the impugned order that there was no adverse inference sought to be made with regard to the eligibility to claim deduction

SRI ALAGAPPA MUTHIAH(HUF),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE-2(4), BANGALORE

In the result, both the appeals of the assessees are allowed\nand revenue appeals are dismissed

ITA 775/BANG/2024[2017-18]Status: DisposedITAT Bangalore12 Aug 2024AY 2017-18
Section 131

54F, 54G and 54H shall be\nchargeable to income tax under the head capital gains\nand by legal fiction it is deemed to be the income of the\nprevious year in which the transfer took place. The\nmode of computation as prescribed under Section 48\nwould indicate that the income chargeable under the\nhead capital gains shall be computed

SRI ALAGAPPA ANNAMALAI(HUF),BANGALORE vs. DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(4), BANGALORE

In the result, both the appeals of the assessees are allowed\nand revenue appeals are dismissed

ITA 776/BANG/2024[2017-18]Status: DisposedITAT Bangalore12 Aug 2024AY 2017-18
Section 131

54F, 54G and 54H shall be\nchargeable to income tax under the head capital gains\nand by legal fiction it is deemed to be the income of the\nprevious year in which the transfer took place. The\nmode of computation as prescribed under Section 48\nwould indicate that the income chargeable under the\nhead capital gains shall be computed

SRI. C. RAMAIAH REDDYT vs. DCIT,

In the result, ITA No.1778/Bang/2012 (A

ITA 1778/BANG/2013[2011-12]Status: DisposedITAT Bangalore10 Apr 2015AY 2011-12

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri V. Srinivasan, C.AFor Respondent: Shri A.K. Ganesh Rao, CIT-III(DR)
Section 132Section 143(3)Section 153ASection 45(2)Section 48

54F, 54G and 54H, be chargeable to income-tax under the head "Capital gains", and shall be deemed to be the income of the previous year in which the transfer took place. (1A) …….. (2) Notwithstanding anything contained in sub-section (1), the profits or gains arising from the transfer by way of conversion by the owner of a capital asset

SRI. C. RAMAIAH REDDYT vs. DCIT,

In the result, ITA No.1778/Bang/2012 (A

ITA 1779/BANG/2013[2012-13]Status: DisposedITAT Bangalore10 Apr 2015AY 2012-13

Bench: Shri N.V. Vasudevan & Shri Jason P. Boaz

For Appellant: Shri V. Srinivasan, C.AFor Respondent: Shri A.K. Ganesh Rao, CIT-III(DR)
Section 132Section 143(3)Section 153ASection 45(2)Section 48

54F, 54G and 54H, be chargeable to income-tax under the head "Capital gains", and shall be deemed to be the income of the previous year in which the transfer took place. (1A) …….. (2) Notwithstanding anything contained in sub-section (1), the profits or gains arising from the transfer by way of conversion by the owner of a capital asset

DEPUTY COMMISSIONER OF INCOME-TAX, CENTRAL CIRCLE-2(4), BENGALURU vs. ALAGAPPA ANNAMALAI (HUF), BENGALURU

The appeals of the assessees are allowed\nand revenue appeals are dismissed

ITA 955/BANG/2024[2017-18]Status: DisposedITAT Bangalore12 Aug 2024AY 2017-18
Section 131

54F, 54G and 54H shall be\nchargeable to income tax under the head capital gains\nand by legal fiction it is deemed to be the income of the\nprevious year in which the transfer took place. The\nmode of computation as prescribed under Section 48\nwould indicate that the income chargeable under the\nhead capital gains shall be computed

G VIJAY PADMA ,BANGALORE vs. INCOME TAX OFFICER WARD-7(2)(1), BANGALORE

In the result, the assessee's appeal is dismissed

ITA 3295/BANG/2018[2007-08]Status: DisposedITAT Bangalore11 Sept 2020AY 2007-08

Bench: Shri Chandra Poojari & Smt. Beena Pillaismt. G Vijay Padma, No.206, 1St Floor, 10Th D Main, 5Th Cross, 1St Block, Jayanagar, Bengaluru-560 011 Pan Abcpv 8123E ….Appellant Vs. Income Tax Officer, Ward 7(2)(1), Bengaluru. ……Respondent. Assessee By: Shri P. R. Mathad, C.A. Revenue By: Smt. R. Premi, Jcit (D.R)

For Appellant: Shri P. R. Mathad, C.AFor Respondent: Smt. R. Premi, JCIT (D.R)
Section 133ASection 143(3)Section 148Section 2(14)(iii)Section 54F

54F of the Act of Rs.16 lakhs for want of evidences. The assessee filed an appeal with the CIT (Appeals) who concurred with the view taken by the Assessing Officer on the issues and dismissed the assessee's appeal. The assessee is once againg in appeal before us. 5. The learned Authorised Representative submitted that appellant owns agricultural land

T. SHIVAKUMAR,BANGALORE vs. ITO, BANGALORE

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

ITA 323/BANG/2015[2009-10]Status: DisposedITAT Bangalore19 Feb 2016AY 2009-10

Bench: Shri Abraham P George & Shri Vijaypal Rao

For Appellant: Shri C. Ramesh, CAFor Respondent: Smt. S. Praveena, Addl.CIT
Section 54

54F of the Act. However, the CIT(A) was not impressed by the above argument. According to him, the original agreement stated to have been entered with Shri T.Vijayakumar did not create enforceable right in favour of the assessee. According to learned CIT(A), assessee had given the money to his brother for helping the latter to acquire