KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH,UK vs. JCIT (OSD) INTL. TAXATION, CIRCLE, CHANDIGARH

In the result, all the appeals of the assessee stands allowed

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

KARNAIL SINGH vs. THE ASSISTANT DIRECTOR OF INCOME TAX, CHANDIGARH

In the result, ground no. 9 of the assessee’s appeal is allowed in favour of the assessee and against the Revenue

Bench: Us.

house property”. Thereafter, the AO analyze the provisions of Article 12 of Indo-UK DTAA as well as definition of interest as per Section 2(28A) of the Act and has held that the money paid by the assessee to M/s Omaxe Ltd. is a capital investment for purchase of the property, the assessee will get back the capital asset

M/S SINGLA BUILDERS AND PROMOTERS LIMITED,RUPNAGAR, PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

Housing Park (Phase-1 and Phase-2) 15.11.2022 Chandigarh-Ambala Highway, Derabassi 3. SBP Homes-1, Sector-126, Kharar, SAS Nagar,Mohali 19.10.2022 4. SBP Homes-2, Sector-126, Kharar, SAS Nagar, Mohali 20.10.2022 It was thus contended by the assessee that the inspection continued to be carried out in the month of October, 2022 and November

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

Housing Park (Phase-1 and Phase-2) 15.11.2022 Chandigarh-Ambala Highway, Derabassi 3. SBP Homes-1, Sector-126, Kharar, SAS Nagar,Mohali 19.10.2022 4. SBP Homes-2, Sector-126, Kharar, SAS Nagar, Mohali 20.10.2022 It was thus contended by the assessee that the inspection continued to be carried out in the month of October, 2022 and November

M/S CREDO ASSETS PVT. LTD.,RUPNAGAR PUNJAB vs. DCIT/ACIT(CEN)-1 CHD, CHANDIGARH

The appeals stand partly allowed

Bench: Hon’Ble Shri Rajpal Yadav & Hon’Ble Shri Manoj Kumar Aggarwal, Am 1. आयकर अपील सं./ Ita No.487/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2013-14) M/S Singla Builders & Promoters Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aaocs-6503-M (अपीलाथ"/Appellant) : (""थ" / Respondent) & 2. आयकर अपील सं. / Ita No.482/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2017-18) & 3. आयकर अपील सं. / Ita No.484/Chandi/2025 (िनधा"रण वष" / Assessment Year: 2018-19) M/S Credo Assets Private Ltd. Dcit / Acit Central-1 बनाम/ Plot No 1265-C, Sector 82, Industrial Area C.R. Building, Sector 17 Vs. Rupnagar (Punjab) 140308 Chandigarh-160017 "थायीलेखासं./जीआइआरसं./Pan/Gir No. Aafcc-6400-L (अपीलाथ"/Appellant) : (""थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Sh. Parikshit Aggarwal (Ca) & Smt. Shruti Khandelwal (Ca) – Ld. Ars ""थ"कीओरसे/Respondent By : Smt. Kusum Bansal (Cit) & Shri Rajat Kumar Kureel (Cit) – Ld. Drs (Virtual) Date Of Final Hearing : 27-01-2026 Date Of Pronouncement : 03-02-2026

Housing Park (Phase-1 and Phase-2) 15.11.2022 Chandigarh-Ambala Highway, Derabassi 3. SBP Homes-1, Sector-126, Kharar, SAS Nagar,Mohali 19.10.2022 4. SBP Homes-2, Sector-126, Kharar, SAS Nagar, Mohali 20.10.2022 It was thus contended by the assessee that the inspection continued to be carried out in the month of October, 2022 and November

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

M/S MANAV MANGAL SOCIETY,CHANDIGARH vs. DCIT, C-1, (E), CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

192 7,62,732 66,250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

192 7,62,732 66,250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

192 7,62,732 66,250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars

DCIT, C-1, (E), CHANDIGARH vs. M/S MANAV MANGAL SOCIETY, CHANDIGARH

In the result, all the appeals of the assessee are allowed and all the appeals of the department are dismissed

192 7,62,732 66,250 Dev Chaudhary, # 3085 Sector 21 D, Chandigarh 8. Gian Singh Salary Rent Interest Salary Rent Interest Salary Rent Interest Sardana S/o Sh. 14,40,00 0 2,05,459 18,80,00 0 2,191 24,16,00 0 5,000 J.R. Sardana, Manav Mangal High School, Sector 21 C, Chandigarh Particulars