RENU DEVI,PATNA vs. ITO, PATNA
In the result, the appeal of the assessee is allowed for statistical purposes
ITA 672/PAT/2024[2016-17]Status: DisposedITAT Patna25 Aug 2025AY 2016-17
Bench: Shri Duvvuru Rl Reddy, Vice-(Kz) I.T.A. No. 672/Pat/2024 Assessment Year: 2016-2017 Renu Devi,……………………………....….………Appellant D/79, P.C. Colony, Lohia Nagar, Kankarbagh, Patna-800020, Bihar [Pan:Algpd4522P] -Vs.- Income Tax Officer,………………………...…….Respondent Ward-6(2), Patna Appearances By: Shri Sudipta Sannigrahi, C.A., Appeared On Behalf Of The Assessee Shri Ashwani Kr. Singal, Jcit, Appeared On Behalf Of The Revenue Date Of Concluding The Hearing: June 24, 2025 Date Of Pronouncing The Order: August 25, 2025 O R D E R
Section 144Section 148Section 2(47)(v)Section 271(1)(c)Section 45Section 48
capital gains as on the date of JDA is to be considered. Besides section 45(5A) being a substantive position cannot be applied to the Development Agreement entered before the insertion of this section and, therefore, automatically section 2(47)(v) gets attracted. The ld. Addl./JCIT(Appeals) also held that section 45(5A) is a substantive provision, which