SH. MAHESH CHUGH,CHANDIGARH vs. PR.CIT-2, CHANDIGARH

In the result, the appeal of the assessee is allowed

section 263 of the Income Tax Act, 1961 in the interest of Justice and Oblige. (emphasis supplied) 13.2 Considering this, the ld. PCIT passed the following order on facts: 3. The assessee purchased a residential house No. 3113, Sector 28-D, Chandigarh for total consideration of Rs. 2,89,80,000/- in which the share of the assessee

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH, CHANDIGARH vs. DEEP KAUR PANNU THROUGH L/H RANJI SINGH PANNU & GURBILAS PLATO SINGH PANNU, CHANDIGARH

In the result, appeal of the Revenue is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 987/Chd/2024 "नधा"रण वष" / Assessment Year : 2016-17 Dcit, Deep Kaur Pannu, Circle 1(1), बनाम # 1070, Chandigarh Sector 15-B, Vs. Chandigarh "थायी लेखा सं./Pan No: Abmpk1575B अपीलाथ"/Appellant ""यथ"/Respondent ( Physical Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Manoj Goyal, Ca राज"व क" ओर से/ Revenue By : Shri Manav Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 22.05.2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 07.08.2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 24.7.2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

disallowing deduction under section 54F by ignoring the fact that fractional ownership right in one residential property cannot be equated

SHRI PARDEEP KUMAR JAIN,ZIRAKPUR vs. ITO, W-2(3), CHANDIGARH

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

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaआयकरअपीलसं./Ita No. 190/Chd/2019 "नधा"रणवष" / Assessment Year : 2012-13 Shri Pradeep Kumar Jain, The Ito, Ward 2(3), बनाम Chandigarh Flat No.222, Orbit Apartments, 6Th Floor, Zirakpur "थायीलेखासं./Pan No: Advpj6719P अपीलाथ"/Appellant ""यथ"/Respondent

disallowance so made by the Assessing Officer. The assessee, thus, has come in appeal before us. 8. We have heard the rival contentions of the Ld. Authorized Representatives of both the parties and gone through the record. From the facts it is revealed that after the sale of the share in the residential property, the assessee invested

ACIT, CIRCLE, SHIMLA vs. SHRI VINOD SHARMA, NEW DELHI

In the result, the appeal of the Revenue is dismissed

Bench: Shri A.D. Jain & Dr Krinwant Sahayआयकर अपील सं./ Ita No. 1449/Chd/2019 "नधा"रण वष" / Assessment Year: 2015-16 The Acit, Vs. Shri Vinod Sharma, बनाम B-1/3, Circle, Safdarjang Enclave, Shimla New Delhi 110029 "थायी लेखा सं./Pan No: Abkps1560N अपीलाथ"/ Appellant ""यथ"/ Repsondent (Hybrid Mode ) "नधा"रती क" ओर से/Assessee By : Sh. Vishal Mohan, Sr. Advocate With Shri Ahninav Bazwaria, Advocate राज"व क" ओर से/ Revenue By : Smt. Kusum Bansal, Cit Dr सुनवाई क" तार"ख/Date Of Hearing : 10.06.2024 उदघोषणा क" तार"ख/Date Of Pronouncement : 09.07.2024

disallowance of deduction u/s 54F of the Act. During the assessment proceedings, the A.O. noticed that Long Term Capital Gains at Rs.4,57,96,153/- have accrued to the assessee on account of sale of shares. The assessee has claimed a deduction u/s 54F of the Act 1449-Chd-2019 Vinod Sharma, New Delhi 4 amounting to Rs.4

ACIT, INTL. TAXATION, CIRCLE, CHANDIGARH vs. SH. MANJIT SINGH BAIDWAN, CHANDIGARH

In the result, the appeal of the Revenue is dismissed

Bench: Shri N.K. Saini & Shri R.L Negiआयकर अपील सं./Ita No. 1245/Chd/2018 "नधा"रण वष" / Assessment Year : 2013-14 The Acit, Sh. Manjit Singh Baidwan, बनाम (International Taxation), # 3151, Sector 27-D, Chandigarh Chandigarh

disallowance of the exemption / deduction claimed by the assessee u/s 54 of the Act and addition of Rs. 21,478/- i.e., on account of difference of actual amount of interest received by the assessee and the amount declared by the assessee. The assessee challenged the action of the AO in making addition of Rs.4,72,98,280/- before

SHRI PRINCEPREETJIT SINGH,RANJIT NAGAR vs. PR.CIT-1, CHANDIGARH

In the result, appeal of the assessee is allowed

Bench: SHRI. RAJPAL YADAV (Vice President), SHRI. KRINWANT SAHAY (Accountant Member)

sections are identical—ensuring that where capital gains are reinvested in qualifying assets, the benefit of exemption should be granted, even if such reinvestment occurs before formal execution of the transfer deed. This interpretation has received judicial recognition in multiple cases, including:  DCIT v Assa Singh in ITA No. 26/Asr/2015 dated 11.3.2016, ITAT Amritsar.  Ramesh Narhari Jakhadi

SEEMA SALWAHAN,AMBALA CANTT. vs. INCOME TAX OFFICER, WARD-4, AMBALA CANTT

In the result, the appeal of the assessee is allowed

Bench: Shri Rajpal Yadav

disallowed the claim of assessee under Section 54F amounting to Rs.28,92,978/-. The AO has initiated a penalty under

SH. JASMER SINGH S/O SH. JEET SINGH,KURUKSHETRA vs. ITO, KURUKSHETRA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2013-14

disallowance of exemption under section 54B on the grounds that investment in agricultural land has been made in the hands of son without appreciating the fact that the investment of claim of exemption u/s 54B has been made by appellant (Father) out of sale proceeds of land. 3. Brief facts of the case are that the assessee has sold agricultural

SH. GURMEET SINGH S/O SH. GURBACHAN SINGH,KURUKSHETRA vs. ITO, KURUKSHETRA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2013-14

disallowance of exemption under section 54B on the grounds that investment in agricultural land has been made in the hands of son without appreciating the fact that the investment of claim of exemption u/s 54B has been made by appellant (Father) out of sale proceeds of land. 3. Brief facts of the case are that the assessee has sold agricultural

SH. GURDEEP SINGH S/O SH. GURBACHAN SINGH,KURUKSHETRA vs. ITO, KURUKSHETRA

Bench: Smt. Diva Singh & Dr. B.R.R. Kumarassessment Year: 2013-14

disallowance of exemption under section 54B on the grounds that investment in agricultural land has been made in the hands of son without appreciating the fact that the investment of claim of exemption u/s 54B has been made by appellant (Father) out of sale proceeds of land. 3. Brief facts of the case are that the assessee has sold agricultural

SHRI VINOD SHARMA,NEW DELHI vs. ACIT, CIRCLE, SHIMLA

In the result, Assessee’s appeal is partly allowed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1340/Chd/2019 "नधा"रण वष" / Assessment Year : 2015-16 Vinod Sharma, Acit, बनाम B-1/3, Safdarjang Enclave, Circle, New Delhi-110029. Shimla. Vs. "थायी लेखा सं./Pan No: Abkps1560N अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing) "नधा"रती क" ओर से/Assessee By : Shri. Vishal Mohan, Sr. Advocate With Shri Abhinav, Advocate (Virtual Mode) राज"व क" ओर से/ Revenue By : Dr. Ranjit Kaur, Addl. Cit, Sr.Dr सुनवाई क" तार"ख/Date Of Hearing : 14-05-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 06- 08-2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Assessee Against The Order Dated 16-08-2019 Of Ld. Commissioner Of Income Tax (Appeals), Shimla H.P. [ Herein Referred To As ‘Cit(A)’]

Disallowance is bad in law and facts and is not sustainable in the eyes of law. 2. That in the facts and circumstances of the case the Ld Commissioner of Income Tax (Appeals) is not justified in treating the one-time maintenance deposits of Rs. 7,70,625/ paid by the appellant not as cost of acquisition of the property

DEPUTY COMMISSIONER OF INCOME TAX, CIRCLE-1(1), CHANDIGARH vs. POONAM KHETRAPAL SINGH, CHANDIGARH

In the result, appeal is dismissed

Bench: Shri Rajpal Yadav & Shri Krinwant Sahayआयकर अपील सं./ Ita No. 1000/Chd/2024 "नधा"रण वष" / Assessment Year : 2021-22 Dcit, Poonam Khetrapal Singh, बनाम Circle 1(1), H. No 816, Sector 16, Chandigarh Chandigarh. Vs. "थायी लेखा सं./Pan No: Anqps6367R अपीलाथ"/Appellant ""यथ"/Respondent ( Hybrid Hearing ) "नधा"रती क" ओर से/Assessee By : Sh. Ashish Kumar Singh, Advocate राज"व क" ओर से/ Revenue By : Smt Kusum Bansal, Cit Dr (Virtual Mode) सुनवाई क" तार"ख/Date Of Hearing : 15-05-2025 उदघोषणा क" तार"ख/Date Of Pronouncement : 06-08-2025 आदेश/Order Per Krinwant Sahay, Am: Appeal In This Case Has Been Filed By The Revenue Against The Order Dated 29.7.2024 Of Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi.

section 54F. The AO is directed to allow the deduction u/s.54F on the entire capital gain as calculated by the assessee in the return of income. The grounds taken in this issue is therefore allowed.” 4. Per contra, the Ld. DR relied on the order of the AO. 5. We have considered the findings given by the Assessing Officer

KESHAV DUTT SHREEDHAR,SHIMLA vs. DCIT, SHIMLA

In the result, appeal of the assessee is allowed

disallowed. Thus the capital gain amount of Rs. 3861259/- needed to be added back to taxable income and charged to tax.” 2.5 In the said background it was his submission referring to the relevant provision namely sub-section (1) of section 54 of the Income Tax Act that the law does not require that it is the same money which

PREM SINGH,CHAMBA vs. ACIT CIRCLE PALAMPUR, PALAMPUR

In the result, the appeal for AY 2017-18 stands partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं. / Ita No. 946/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2015-16) & 2. आयकर अपील सं. / Ita No. 947/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) Shri Prem Singh Dcit Circle, Palampur बनाम/ The Palace. Chamba Himachal Pradesh - 176061 Vs. Himachal Pradesh – 176310 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aampr-8876-P (अपीलाथ"/Appellant) : (""थ" / Respondent) Assessee By : Shri Ajay Jain (Ca) – Ld. Ar Revenue By : Shri Bharat Bhushan Garg (Cit) (Virtual) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 13-11-2025 घोषणाकीतारीख /Date Of Pronouncement : 13-01-2026 आदेश / O R D E R Manoj Kumar Aggarwal () 1. The Assessee Is In Further Appeals Before Us For Assessment Years (Ay) 2015-16 & 2017-18 Which Arises Out Of Separate Orders Of Learned First Appellate Authority. First, We Take Up Appeal For Assessment Year (Ay) 2015-16 Which Arises Out Of An Order Of Learned Commissioner Of Income Tax (Appeals), Nfac [Cit(A)] Dated 22-07-2025 In The Matter Of An Assessment Framed By Ld. Assessing Officer [Ao] U/S 143(3) Of The Act On 29-12-2017. The Assessee Is Aggrieved By Computation Of Capital

Disallowing a sum of Rs.1,25,00,000 claimed as deduction on account of lawyer fees on the ground that the same was not entitled for deduction under section 48 while calculating the amount of capital gain even though the same has been incurred in relation to the transfer of the house under consideration and entitled for deduction

SH. DINESH DUA,DELHI vs. DCIT, CHANDIGARH

In the result, the appeal of the assessee is treated as partly

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2008-09

section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word ‘assess’ has been used in the context of abated proceedings and ‘reassess’ has been used for completed assessment proceedings, which would not abate as they are not pending on the date of initiation of the search or making of requisition and which

SHRI DINESH DUA,DELHI vs. DCIT, CHANDIGARH

In the result, the appeal of the assessee is treated as partly

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2008-09

section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word ‘assess’ has been used in the context of abated proceedings and ‘reassess’ has been used for completed assessment proceedings, which would not abate as they are not pending on the date of initiation of the search or making of requisition and which

SH.DINESH DUA,DELHI vs. DCIT, CHANDIGARH

In the result, the appeal of the assessee is treated as partly

Bench: Shri Sanjay Garg & Ms. Annapurna Guptaassessment Year : 2008-09

section and a harmonious construction of the entire provision would lead to an irresistible conclusion that the word ‘assess’ has been used in the context of abated proceedings and ‘reassess’ has been used for completed assessment proceedings, which would not abate as they are not pending on the date of initiation of the search or making of requisition and which

MANPREET SINGH BHULLAR,PARWANOO vs. ITO, PARWANOO

In the result, appeal of the assessee is allowed

section 54 against sale of commercial building which was denied by AO not being residential house. Alternate claim of 54F was also denied as at the time of inspection the residential house acquired was also demolished and site was used for construction of hospital. The disallowance