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11 results for “transfer pricing”+ Section 54Fclear

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Key Topics

Section 54F29Section 14819Section 143(3)13Section 1479Capital Gains7Section 148A6Deduction6Section 545Section 2635Section 144

DCIT., (INTERNATIONAL TAXATION)-1, HYDERABAD vs. SYAMA REDDY MALI REDDY, HYDERABAD

ITA 366/HYD/2025[2019-20]Status: DisposedITAT Hyderabad03 Sept 2025AY 2019-20
Section 143(2)Section 143(3)Section 144C(3)Section 54Section 54F

54F being analogous section calls for a more\nliberal interpretation and application as the intent of the section was to\nencourage an investment in residential house by an individual or a Hindu\nUndivided family out of the sale proceeds earned. This view has been held\nconsistently by various appellate authorities.\nThe Hon'ble Apex court as early

HIMASAGAR KRISHNA MUTHAPPAGARI,TIRUPATI vs. ITO., WARD-2(3), TIRUPATI

ITA 687/HYD/2024[2016-17]Status: DisposedITAT Hyderabad12 Mar 2025
4
Exemption4
Addition to Income4
AY 2016-17

Bench: Us.

For Appellant: Shri M. Uday Teja, C.AFor Respondent: Ms. M. Narmada, CIT-DR
Section 143(3)Section 147Section 148Section 263

Transfer Pricing Officer" shall have the same meaning as assigned to it in the Explanation to section 92CA.] (2) No order shall be made under sub-section (1) after the expiry of two years from the end of the financial year in which the order sought to be revised was passed. (3) Notwithstanding anything contained in sub-section

GADDAM MOHAN REDDY,NIZAMABAD vs. INCOME TAX OFFICER, WARD 1, NIZAMABAD, NIZAMABAD

ITA 1685/HYD/2025[2013-14]Status: DisposedITAT Hyderabad24 Dec 2025AY 2013-14

Bench: the AO during re-assessment proceedings.4. The authorities below further failed to appreciate that on the same set of facts, the AO with all his expertise on the provisions of the Act has allowed the deduction claimed Under Section 54F of the Act in the assessment order passed Under Section 143(3) r.w.s Section 147 of the Act and that deduction claimed by the appellant Under Section 54F of the Act was by inadvertent.

Section 143(3)Section 147Section 148Section 263Section 271(1)(c)Section 54Section 54F

54F of the Act of Rs.16,29,727/- pertaining to the STCG arising on the transfer of 517.87 sq yds of land (out of 1041.34 sq yds). 8. Aggrieved, the assessee assailed the order passed by the AO under section 271(1)(c) of the Act, dated 28/09/2022, before the CIT(A) but without success. 9. The assessee being aggrieved

RACHIT V SHAH,HYDERABAD vs. ITO, WARD-7(3), HYDERABAD

In the result, the appeal of the assessee is dismissed

ITA 420/HYD/2022[2015-16]Status: DisposedITAT Hyderabad15 Mar 2023AY 2015-16

Bench: Shri Rama Kanta Panda & Shri Laliet Kumar

For Appellant: Shri Sunil Kumar Jain, CAFor Respondent: Shri Kumar Adithya for Shri K.P.R.R.Murthy, Sr.AR
Section 142(1)Section 143(1)Section 143(3)Section 54F

transfer of Capital Asset the assessee owned only one residential house (@ Avanthi Nagar). The assessee sold the capital asset and invested the proceeds in a new residential house property and thereby fulfilled the conditions of section 54F of the Income Tax Act, 1961 to claim exemption. Hence, the intention of the CIT (A) is totally wrong, bad & illegal. The Appellant

MAHARSHI GOGINENI ,HYDERABAD vs. ASST. COMMISSIONER OF INCOME TAX, CIRCLE-14(1), HYDERABAD

In the result, appeal of assessee is allowed in part

ITA 1644/HYD/2019[2015-16]Status: DisposedITAT Hyderabad31 Jul 2023AY 2015-16

Bench: Shri Rama Kanta Panda & Shri K. Narasimha Chary

For Appellant: Shri K.A. Sai Prasad, AR
Section 54F

price by payment of kind or adjustment of old debt or other monetary considerations. It was observed that if you sell a house and make profit, pay Caesar (State) but if you buy a house or build another and thereby satisfy Page 4 of 8 the conditions of Section 54, you were exempt. The purpose was plain; the symmetry

INCOME TAX OFFICER, WARD-1, CHITTOOR vs. G VIJAYASIMHA REDDY, BENGALURU

In the result, the appeal of Revenue in ITA

ITA 376/HYD/2023[2015-16]Status: HeardITAT Hyderabad05 Jan 2024AY 2015-16

Bench: Shri R.K. Panda & Shri Laliet Kumar

For Appellant: Shri Y V Bhanu NarayanFor Respondent: Ms. Sheetal Sarin, Sr. AR
Section 148Section 2(13)Section 54F

54F. For all the above reasons discussed above the request of the assessee vide his letter dated 11.12 2017 received in this office on 15.12.2017 to consider the receipts from the project as capital gains is hereby rejected and the receipts from the project are treated as business income only and assessment is completed accordingly and penalty proceedings

INCOME TAX OFFICER (INTERNATIONAL TAXATION)-1, HYDERABAD vs. ARUNA GULLAPALLI, HYDERABAD

ITA 339/HYD/2021[2017-18]Status: DisposedITAT Hyderabad31 Jan 2023AY 2017-18

Bench: Shri R.K. Panda & Shri Laliet Kumarassessment Year: 2017-18 Income Tax Officer, Vs. Aruna Gullapalli, (International Taxation) – 1, Hyderabad. Hyderabad. Pan No.Bfhpg9489L. (Appellant) (Respondent) Assessee By: Shri P. Murali Mohan Rao Revenue By: Shri Kumar Adithya Date Of Hearing: 23.01.2023 Date Of Pronouncement: 31.01.2023

For Appellant: Shri P. Murali Mohan RaoFor Respondent: Shri Kumar Adithya
Section 144Section 250(4)Section 48Section 54FSection 69

section, hold that the fact of utilization of sale proceeds in property, though not registered during the specified period would qualify for the benefit of reinvestment.-- 12.4 For availing exemption u/s 54F, the net consideration should be invested in specified asset before the date of filing return u/s 139. It was held in Nipun Mehrotra vs. ACIT

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

In the result, appeal of the assessee for the assessment year 2020-2021 is allowed for statistical purposes

ITA 1528/HYD/2025[2020-2021]Status: DisposedITAT Hyderabad28 Nov 2025AY 2020-2021

Bench: Shri Vijay Pal Rao & Shri Madhusudan Sawdiaआ.अपी.सं /Ita Nos.1527 & 1528/Hyd/2025 Assessment Years – 2016-2017 & 2020-2021 Brijesh Chandwani The Dcit, Circle-6(1), Vs. Hyderabad – 500 034 Hyderabad. Pan Adkpc1537H (Appellant) (Respondent) िनधा"रती "ारा /Assessee By: Ca Pawan Kumar Chakrapani राज" व "ारा /Revenue By: Sri Ranjan Agrawala, Sr. Ar

For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR
Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

Section 54F allows exemption of capital gains if the net sale consideration from the transfer of a long-term capital asset (other than a residential house) is invested in the purchase or construction of one residential house within the prescribed time limits. The "cost of the new asset includes both the purchase price

BRIJESH CHANDWANI,HYDERABAD vs. DCIT., CIRCLE -6(1), HYDERABAD

ITA 1527/HYD/2025[2016-2017]Status: DisposedITAT Hyderabad28 Nov 2025AY 2016-2017
For Appellant: CA Pawan Kumar ChakrapaniFor Respondent: Sri Ranjan Agrawala, Sr. AR
Section 133ASection 143(1)(a)Section 143(3)Section 147Section 148Section 148ASection 234A

Section 54F allows exemption of capital gains if the net sale consideration from the transfer of a long-term capital asset (other than a residential house) is invested in the purchase or construction of one residential house within the prescribed time limits. The \"cost of the new asset includes both the purchase price

SUBBA RAJU CHEKURI,HYDERABAD vs. ITO, WARD 11(3), SIGNATURE TOWER, KONDAPUR

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 433/HYD/2023[2012-13]Status: DisposedITAT Hyderabad12 Sept 2023AY 2012-13

Bench: Shri Laliet Kumarassessment Year: 2012-13 Subba Raju Chekuri, Vs. The Income Tax Officer, Ward 11(3), R/O. Hyderabad. Signature Tower, Kondapur, Pan : Aempc1025M. R.R. District, Hyderabad. (Appellant) (Respondent) Assessee By: Sri H. Srinivasulu. Revenue By: Sri Aravindakshan, Sr. A.R. 12.09.2023 Date Of Hearing: Date Of Pronouncement: 12.09.2023

For Appellant: Sri H. SrinivasuluFor Respondent: Sri Aravindakshan, Sr. A.R
Section 142(1)Section 144Section 147Section 148Section 50CSection 50C(2)Section 54F

54F of the Act. 6. Ld A.O erred in computing the capital Gains on transfer of rights on immovable property at a sum of Rs. 46,74,945. The appellant is not the legal owner of the property. 7. Ld A.O failed to appreciate that the appellant was only an agreement holder cum GPA and the provisions of section

NEMI CHAND,GUDUR vs. ITO., WARD-1, GUDUR

In the result, appeal filed by the assessee is partly allowed in terms of our aforesaid observations

ITA 1288/HYD/2025[2018-19]Status: DisposedITAT Hyderabad26 Nov 2025AY 2018-19

Bench: Shri Manjunatha G. & Shri Ravish Soodआ.अपी.सं /Ita No.1288/Hyd/2025 (िनधा"रण वष"/Assessment Year: 2018-19) Nemi Chand, Vs. Income Tax Officer, 1-2-8/11A, 302, 3Rd Floor, Ward-1, Srinivas Street No.1, Guduru. Himayat Nagar, Hyderabad, Telangana. Pan: Achpr2242L (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Sri Sridhar Jhawar, Ca राज" व "ारा/Revenue By: Dr. Sachin Kumar, Sr. Ar सुनवाई की तारीख/Date Of Hearing: 12/11/2025 घोषणा की तारीख/Date Of 26/11/2025 Pronouncement: आदेश / Order Per. Ravish Sood, J.M: The Present Appeal Filed By The Assessee Is Directed Against The Order Passed By The Commissioner Of Income Tax (Appeals), National Faceless Appeal Centre, Delhi, Dated 13/06/2025 Which In Turn Arises From The Order Passed By The Assessing Officer Under Section 143(3) R.W.S 144B Of The Income-Tax Act, 1961 (For Short, “Act”), Dated 23/04/2021 For The Assessment Year 2018-19. The Assessee Has 2 Nemi Chand Vs. Ito Assailed The Impugned Order On The Following Grounds Of Appeal Before Us: 1. “Whether On The Facts & Circumstances Of The Case & In Law Whether The Order Of The Learned Commissioner Of Income Tax Was Pervasive In Considering The Income From Capital Gains As Business Income In Terms Of Provisions Of Section 2(14) Read With Section 2(47) 2. Whether On The Facts & Circumstances Of The Case & In Law. Whare Capital Gain Was Invested In Purchase/Construction Of Residential House Within Time Limit Prescribed Under Section 2 54(1), Assessment Order Allowing Assesses Claim Under Section 54 Could Not Be Treated As Erroneous & Prejudicial To Interest Of Revenue Only Because Capital Gain Was Not Deposited In Capital Gain Account Scheme. 3. Any Other Ground (If Any) That May Be Urged At The Time Of Hearing.”

For Appellant: Sri Sridhar Jhawar, CAFor Respondent: Dr. Sachin Kumar, Sr. AR
Section 143(3)Section 2Section 2(14)Section 2(47)Section 54

54F of the Act is infructuous and is dismissed. Thus grounds of appeal no. 5 & 6 are dismissed. 6.3 Ground of appeal No. 7: The ground of appeal No. 7 relates to charging interest under section 234C. 6.3.1 This ground pertains to appellant's contention that AO wrongly charged interest 234C of the Act. Charging of such interest is consequential