MADHU KUMAR PATEL,HYDERABAD vs. ADIT,(INT. TAXN)-2, HYDERABAD
In the result, the appeal of the assessee is allowed for statistical purposes
ITA 395/HYD/2022[2015-16]Status: DisposedITAT Hyderabad26 Dec 2022AY 2015-16
Bench: Shri R.K. Panda & Shri K. Narasimha Charyassessment Year:2015-16 Shri Madhu Kumar Patel Vs. A.D.I.T (Intl.Taxation)-2 Hyderabad Hyderabad Pan:Bvdpp3797G (Appellant) (Respondent) Assessee By: Shri K.A. Sai Prasad, Ca Revenue By: Shri Rajendra Kumar, Cit(Dr) Date Of Hearing: 10/11/2022 Date Of Pronouncement: 26/12/2022 Order Per R.K. Panda, A.M This Appeal Filed By The Assessee Is Directed Against The Order Dated 19.7.2022 Passed U/S 147 R.W.S. 144C(13) Of The I.T. Act For The A.Y 2015-16. 2. Facts Of The Case, In Brief, Are That The Assessee Is An Individual & A Resident Of The U.K. He Filed His Return Of Income On 31.08.2015 Declaring Total Income At Rs.2,91,07,000/- As Income From Long Term Capital Gain.
For Appellant: Shri K.A. Sai Prasad, CAFor Respondent: Shri Rajendra Kumar, CIT(DR)
Section 147Section 148Section 2(47)(v)
section 2(47) of the I.T. Act, 1961 and considering the fact that substantive compliance of the contract had taken place during the financial year 2014-15, the Assessing
Officer held that the capital gain is assessable in A.Y 2015-16 and not in A.Y 2016-17. 7. So far as the issue relating to deemed income being reversal