M/S. MAHINDRA RESIDENTIAL DEVELOPERS LTD.,,KANCHIPURAM vs. ITO, CORPORATE WARD - 4 (1),, CHENNAI

In the result, the appeals of the assessee for AYs 2012-13, 2013-14

Bench: Shri Aby T. Varkey & Shri Jagadishआयकर अपील सं./Ita No.870/Chny/2017 िनधा"रणवष"/Assessment Year: 2012-13 & आयकर अपील सं./Ita Nos.338 & 339/Chny/2020 िनधा"रणवष"/Assessment Years: 2013-14 & 2014-15

section 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. " Mr. Harish Salve, learned counsel appearing for the appellant, without disputing that the grant of a lease would constitute a transfer of an ,asset, has raised the following two contentions

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4), CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

capital gains." In other words, he was proceeding with the scope of the assessment and was not really addressing himself as to the scope of exercising jurisdiction under Chapter XIV-B and section 158BA. The Tribunal, on analysis of the materials placed before it, has recorded the following finding : "In the case in hand admittedly undisclosed income

V RAMAKRISHNAN,CHENNAI vs. DCIT CENTRAL CIRCLE III(4) , CHENNAI

In the result, the appeal for the A

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunatha

capital gains." In other words, he was proceeding with the scope of the assessment and was not really addressing himself as to the scope of exercising jurisdiction under Chapter XIV-B and section 158BA. The Tribunal, on analysis of the materials placed before it, has recorded the following finding : "In the case in hand admittedly undisclosed income

NATESAN EKAMBARAM,CHENNAI vs. DCIT CENTRAL CIRCLE 1(2), CHENNAI

In the result, the ground of appeal raised by the assessee on this issue stands allowed

Bench: Shri Ss Viswanethra Ravi & Shri S.R. Raghunathaआयकरअपीलसं./Ita No.:2873/Chny/2024 धनिाारणिर्ा / Assessment Year: 2014-15 Natesan Ekambaram, Dcit, 1/115, Bajanai Kovil Vs. Central Circle -1(2), Street, Chennai. Perumbakkam, Medavakkam Post, Chennai – 601 302 [Pan:Ackpe-6757-C] (प्रत्यथी/Respondent) (अपीलाथी/Appellant) अपीलाथीकीओरसे/Appellant By : Mr.K.Vishwa Padmanabhan, Ca. प्रत्यथीकीओरसे/Respondent By : Mr.C.Sivakumar , Addl.Cit.

section 2(47) of the Act. 32. In the instant case, the recitals of the registered sale deed dated 14.10.2013 clearly indicate that the full value of consideration for the transfer of 30.35 cents of land to M/s.Jacaranda Properties Private Limited is Rs.1,00,44,000/- only. In law, the recitals of a registered document carry greater evidentiary value unless

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

section 2(14) of the Income Tax Act,1961, which excludes "Agriculture land", from the definition of "Capital Asset", chargeable to capital gains on transfer of such asset. This exemption of agriculture land from taxation existed in income-tax legislation from the 1922 onwards till date, with slight modifications made to the provisions from time to time. He submits that

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

section 2(14) of the Income Tax Act,1961, which excludes "Agriculture land", from the definition of "Capital Asset", chargeable to capital gains on transfer of such asset. This exemption of agriculture land from taxation existed in income-tax legislation from the 1922 onwards till date, with slight modifications made to the provisions from time to time. He submits that

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

section 2(14) of the Income Tax Act,1961, which excludes "Agriculture land", from the definition of "Capital Asset", chargeable to capital gains on transfer of such asset. This exemption of agriculture land from taxation existed in income-tax legislation from the 1922 onwards till date, with slight modifications made to the provisions from time to time. He submits that

SAMARJIT SINGH CHABRA,CHENNAI vs. ITO NON CORPORATE WARD 14(1), CHENNAI

In the result, all the appeals filed by the assessee in ITA No

Bench: Shri S.S. Viswanethra Ravi & Shri Jagadishआयकर अपील सं./I.T.A. Nos.1623, 1624, 1625 & 1646/Chny/2018 िनधा"रण वष"/Assessment Years: 2007-08, 2009-10, 2010-11 & 2008-09 & W.T.A. Nos. 43 & 44/Chny/2018 Assessment Years: 2007-08, 2008-09 Shri Samarijit Singh Chabra, Vs. The Income Tax Officer/ No. K-10, Sangath Apartments, Wealth Tax Officer, Mgr Nagar, Velachery, Non Corporate Ward – 14(1), Chennai 600 042. Chennai. [Pan: Bfops1703Q] (अपीलाथ"/Appellant) (""थ"/Respondent) अपीलाथ" की ओर से / Appellant By : Shri N. Arjun Raj, Advocate ""थ" की ओर से/Respondent By : Shri P. Sajit Kumar, Jcit सुनवाई की तारीख/ Date Of Hearing : 08.05.2024 घोषणा की तारीख /Date Of Pronouncement : 31.07.2024 आदेश /O R D E R Per S.S. Viswanethra Ravi: These Four Income Tax Appeals Filed By The Assessee Are Directed Against Different Orders All Dated 26.02.2018 Passed By The Ld. Commissioner Of Income Tax (Appeals) 14, Chennai For The Assessment Years 2007-08, 2009-10, 2010-11 & 2008-09. 2. Since, Issues Raised In All The Appeals Are Similar Based On The Same Identical Facts, With The Consent Of The Both The Parties, We Proceed

section 2(14) of the Income Tax Act,1961, which excludes "Agriculture land", from the definition of "Capital Asset", chargeable to capital gains on transfer of such asset. This exemption of agriculture land from taxation existed in income-tax legislation from the 1922 onwards till date, with slight modifications made to the provisions from time to time. He submits that

COGNIZANT TECHNOLOGY SOLUTIONS INDIA PRIVATE LTD.,CHENNAI vs. ACIT, LARGE TAXPAYER UNIT-1, CHENNAI

Bench: Shri Mahavir Singh, Hon’Ble & Shrimanjunatha.G, Hon’Bleआयकरअपीलसं./Ita No.269/Chny/2022 िनधा"रणवष"/Assessment Year: 2017-18 V. M/S.Cognizant Technology- The Asst. Commissioner- Solutions India Pvt. Ltd., Of Income Tax, 5/535, Okkiam, Thoriapakkam, Large Taxpayer Unit-1, Old Mahabalipuram Road, Chennai. Chennai-600 096. [Pan:Aaacd 3312 M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri Ajay Vohra, Sr.Counsel For Shri N.V. Balaji, Adv. ""यथ" क" ओर से /Respondent By : Shri R.Shankaranarayanan, Additional Solicitor – General Of India For Shri A.P.Srinivas, Sr. Standing Counsel : सुनवाईक"तारीख/Date Of Hearing 03.07.2023 घोषणाक"तारीख /Date Of Pronouncement : 13.09.2023

capital gains in the hands of the shareholders under section 46A of the Act. 6. The learned CIT(A) has erred in alleging that the "distribution of accumulated profits to shareholders and the 'scheme of arrangement and compromise' is a device designed by the assessee" for repatriation of accumulated profits outside the country without paying

DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE - 1(3), CHENNAI vs. M. MAHADEVAN, CHENNAI

In the result, the appeals of the Revenue are decided as under:-\nITA Nos\nAssessment\nResult\nYear\nPartly allowed

Section 56 of the Income-tax Act, 1961 read with Rule 11UAA and Rule\n11UA. In this context, the appellant has made his submission that the NAV\nof the shares of OCPL as per the Balance sheet as on 31/07/2018 is Rs.11 as\nper Rule 11UA and the same is considered for purposes of business transfer\narrangement. Further

IDFC FINANCIAL HOLDING COMPANY LIMITED,CHENNAI vs. DCIT, CORPORATE CIRCLE-2(2), HENNAI

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

Bench: Shri Aby T. Varkey & Shri Manoj Kumar Aggarwal

37,529/- under the provisions of MAT. Accordingly, the appellant company had paid taxes with interest under MAT provisions of Rs 2,97,79,541/-. 3. The above said book profit includes capital gain of Rs 17,77,44,323/- which arose in 4th quarter only i.e., on 28-02-2018 and 28-03-2018. Accordingly, assessee paid advance

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold

D R BALAKRISHNA RAJA,CHENNAI vs. ACIT, CENTRAL CIR-3(3), CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold

DCIT, CENTRAL CIR-2(4), CHENNAI vs. D R BALAKRISHNA RAJA, CHENNAI

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

Bench: Shri Manu Kumar Giri & Shri S. R. Raghunathaआयकर अपील सं./Ita Nos.:3342 To 3344/Chny/2018 "नधा%रण वष% / Assessment Years: 2011-12 To 2013-14 Shri. D. R. Balakrishna Raja, Acit, 9/16, Venkatesan Street, Vs. Central Circle -3(3), T.Nagar, Chennai. Chennai – 600 017. [Pan:Agwpd-2354-E] (()यथ'/Respondent) (अपीलाथ'/Appellant) आयकर अपील सं./Ita Nos.:91 To 94/Chny/2019 "नधा%रण वष% / Assessment Years: 2011-12 To 2014-15 Dcit, Shri D. R. Balakrishna Raja, Central Circle -2(4), Vs. 9/16, Venkatesan Street, Chennai. T.Nagar, Chennai – 600 017. [Pan:Agwpd-2354-E] (अपीलाथ'/Appellant) (()यथ'/Respondent) Assessee By : Shri. K.G.Raghunath, Advocate Department By : Shri. A R V Sreenivasan, Cit. सुनवाई क5 तार"ख/Date Of Hearing : 27.10.2025 घोषणा क5 तार"ख/Date Of Pronouncement : 19.01.2026 आदेश /O R D E R Per Bench:

capital gains tax. Further, the assessee was not in real estate business. The lands were purchased as agricultural lands, retained by the assessee as agricultural lands and sold as agricultural lands only. The Ld.CIT(A), in para 4.3.20, also rendered a finding that the lands were agricultural land and were in agricultural use till the lands were sold