Bench: Shri Inturi Rama Rao, Am & Shri Sonjoy Sarma, Jm Assessment Year: 2021-22 Thomas Cherian .......... Appellant A-2, Happy House, Sector A9, Navi Mumbai Vashi, Thane 400703 [Pan: Apjpc6676G] Vs. Dcit (International Taxation) .......... Respondent Thiruvananthapuram Appellant By: Shri Vardhaman Jain, Ca Respondent By: Smt. Veni Raj, Cit-Dr Date Of Hearing: 12.06.2025 Date Of Pronouncement: 31.07.2025

gains were wrongly offered to tax by submitting that the property sold was agricultural property situated in rural area and, therefore, it cannot be termed as “capital asset” within the meaning of section 2(14)(iii)(a) & (b) of the Act. Without prejudice to the above, the appellant also objected to adoption of the value for stamp duty purposes