Which cases are most cited on Section 55A?

CIT v. Puja Prints (360 ITR 697) — 88 citing judgments; Hiaben Jayantilal Shah v. ITO (310 ITR 31) — 66 citing judgments; CIT v. Smt. Nilofer I. Singh (309 ITR 233) — 55 citing judgments; 48(SC) 2. Principal Commission of Income Tax v. NDR Promoters (P) Ltd. (96 Taxmann.com 602) — 27 citing judgments; Calcutta in Reliance Jute Industries Ltd. v. Income Tax Officer (150 ITR 643) — 23 citing judgments.

How many judgments are there on Section 55A?

BharatTax indexes 409 ITAT, High Court and Supreme Court judgments that turn on Section 55A of the Income Tax Act, 1961.

Section 55A of the Income Tax Act

Q: What is the leading case on Section 55A of the Income Tax Act?

CIT v. Puja Prints (360 ITR 697) is the decision most relied on for Section 55A, cited in 88 judgments. The amendment to Section 55A(a) of the Income-tax Act, 1961, which replaced "is less than" with "is at variance" as the condition for referring a valuation to a Departmental Valuation Officer, does not have retrospective effect. Consequently, for periods before July 1, 2012, a DVO reference is invalid if the declared value is not "less than" the fair market value.

Income-tax Act, 2025: s.91

Section 55A of the Income-tax Act, 1961 corresponds to section 91 (Reference to Valuation Officer) of the Income-tax Act, 2025.

Read section 91 of the 2025 Act

Correspondence checked against the ICAI tabular mapping of the two Acts and the BharatTax.co section commentary.

The decision most relied on for Section 55A is CIT v. Puja Prints (360 ITR 697), cited in 88 of the 409 judgments on BharatTax that turn on this section.

Leading authorities on Section 55A

CIT v. Puja Prints

360 ITR 697 · 2014 · High Court

citing judgments

The amendment to Section 55A(a) of the Income-tax Act, 1961, which replaced "is less than" with "is at variance" as the condition for referring a valuation to a Departmental Valuation Officer, does not have retrospective effect. Consequently, for periods before July 1, 2012, a DVO reference is invalid if the declared value is not "less than" the fair market value.

Hiaben Jayantilal Shah v. ITO

310 ITR 31 · 2009 · High Court

citing judgments

When an assessee presents a registered valuer's report for an asset, the Assessing Officer, if forming an opinion that the value claimed is less than the fair market value, must refer the valuation to the Valuation Officer under Section 55A(a). The AO cannot unilaterally reject the registered valuer's report or resort to Section 55A(b) in such a scenario.

CIT v. Smt. Nilofer I. Singh

309 ITR 233 · 2009 · High Court

citing judgments

The full value of consideration for computing capital gains under Section 48 refers to the amount stated in the sale deed and cannot be substituted by the market value or a valuation by the DVO under Section 55A, unless there is evidence that the assessee actually received a consideration in excess of the stated amount.

48(SC) 2. Principal Commission of Income Tax v. NDR Promoters (P) Ltd.

96 Taxmann.com 602 · 2018 · High Court

citing judgments

The addition of share capital under Section 68 is unsustainable if the Assessing Officer issues summons to investor entities but receives no appearance, relying solely on submissions via DAK, raising doubts about investor identity and genuineness.

Calcutta in Reliance Jute Industries Ltd. v. Income Tax Officer

150 ITR 643 · 1984 · High Court

citing judgments

The Assessing Officer (AO) is not required to refer the valuation to the District Valuation Officer (DVO) if the AO has conducted a detailed inquiry and is satisfied with the cost of construction. Strict adherence to procedural requirements is essential; failure to comply with mandatory conditions renders the assessment based on such non-compliance invalid.

CWT v. Raghunath Singh Thakur

304 ITR 268 · High Court

citing judgments

The Assessing Officer cannot reject a registered valuer's report without providing specific reasons or making a reference to the valuation, and in such cases, the registered valuer's report shall be accepted.

CIT v. Gauranginiben S. Shodhan Inld. Vs. CIT

45 Taxmann.com 356 · 2014 · High Court

citing judgments

The Assessing Officer cannot reduce the value adopted by the assessee based on a Registered Valuer's report if the value is claimed in accordance with the Registered Valuer's estimate. A reference to the DVO for ascertaining fair market value as on 1.4.1981 was not competent prior to the amendment in section 55A with effect from 1.7.2012.

CIT v. Smt. B.S. Shanthakumar

233 Taxmann 347 · 2015 · High Court

citing judgments

Rs 80,63,610/- in C Block Vasant Vihar. CIT v. Raman Kumar Suri

255 CTR 107 · 2013 · High Court

citing judgments

(i) CIT vs. Nirbhayram Deluram, 224 ITR 610 (SC) (ii) Mega Trends v. CIT

56 Taxmann.com 282 · 2015 · High Court

citing judgments

Judgments on Section 55A

Reshma Dilip Ramrakhyani, Gandhidham vs. ITO Ward 2 Gandhidham, Gandhidham

In the result the grounds of appeal raised by the assessee are allowed”

ITA 895/RJT/2025[2014-15]Status: DisposedITAT Raipur28 Sept 2026AY 2014-15

Bench: Dr. Arjun Lal Saini & Shri Sonjoy Sarmaआयकरअपीलसं./Ita No.895/Rjt/2025 [ "नधा"रणवष"/Assessment Year: 2014-15 ] Reshma Dilip Ramrakhyani, Ito Ward 2, Gandhidham Plot No. 512, Ward 12-C Gandhidham, Vs. Gandhidham Kutch, Gujarat-370201 Gandhidham, Gujarat-370201 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Agnpr4778F (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Kalpesh Doshi, Ld. Ar Respondent By : Shri Genesh Iyer, Ld. Sr. Dr Date Of Hearing : 07/07/2026 28/09/2026 Date Of Pronouncement : :: Order :: Per, Dr. Arjun Lal Saini, Am : Captioned Appeal Filed By The Assessee, Pertaining To Assessment Year (Ay) 2014-15, Is Directed Against The Order Under Section 250 Of The Income- Tax Act, 1961 (Hereinafter Referred To As ‘The Act’) Passed By The National Faceless Appeal Centre (Nac) Delhi/Commissioner Of Income-Tax (Appeals) [In Short ‘Nfac/Ld.Cit(A)’], Dated 26.09.2024, Which In Turn Arises Out Of An Assessment Order Passed By The Assessing Officer U/S 143(3) Of The Act, Dated 21.12.2016. Ita No. 895/Rjt/2025 [ Ay 2014-15 ] Reshma Dilip Ramrakhyani V. Ito

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Genesh Iyer, Ld. Sr. DR

Section 143(3)Section 250Section 5

Reshma Dilip Ramrakhyani, Gandhidham vs. ITO Ward 2 Gandhidham, Gandhidham

In the result the grounds of appeal raised by the assessee are allowed”

ITA 895/RJT/2025[2014-15]Status: DisposedITAT Rajkot28 Sept 2026AY 2014-15

For Appellant: Shri Kalpesh Doshi, Ld. ARFor Respondent: Shri Genesh Iyer, Ld. Sr. DR

Section 143(3)Section 250Section 5

Naghma Mosarrat, Gaya Bihar vs. ITO, Gaya

In the result, Appeal of the Assessee is partly allowed for statistical purposes

ITA 306/PAT/2026[2016-17]Status: DisposedITAT Patna23 Sept 2026AY 2016-17

Bench: Shri Yogesh Kumar U.S. & Shri Rakesh Mishraassessment Year: 2016-17 Naghma Mosarrat Vs. Ito, Ward-3(1), Gaya W/O-Md. Amanullah Ansari, Road No.8, Saddam Chowk Ne Gaya Near Shamsu Kirana Shop, Gaya, Bihar-823001 [Pan: Bfrpm2059E] Appellant Respondent Appellant By : Shri Randheer Kumar, Ca Respondent By : Shri Ravi Kant Chowdhary, Cit, Dr Date Of Hearing : 16.09.2026 Date Of Pronouncement : 23.09.2026 O R D E R Per Yogesh Kumar U.S.: The Present Appeal Is Filed By The Assessee Against The Order Of The Nfac, Delhi (‘Ld. Cit(A)’ For Short) Dated 25.02.2026, Passed U/S 250 Of The Income Tax Act, 1961 (“The Act”, For Short) Pertaining To The Assessment Year 2016-17. 2. There Is A Delay Of 05 Days In Filing The Appeal. The Assessee Filed An Application For Condonation Of Delay. For The Reasons Stated In The Application For Condonation Of Delay, The Delay Of 05 Days In Filing The Present Appeal Is Hereby Condoned. Naghma Mosarrat; A.Y.: 2016-17 3. Brief Facts Of The Case Are That, Assessee Is A Non-Filer. As Per The Information Received On Insight Portal With The Income Chargeable To Tax Had Escaped Assessment For The A.Y. 2016-17 That The Assessee Has Produced The Property To A Sum Of Rs.49,47,000/- & Deposited Cash Of Rs.12,50,350/-. An Assessment Order Came To Be Passed On 19.01.2024 By Making An Addition Of Rs.14,47,000/- On Account Of Income From Other Sources As Per Provisions Of Section 56(2)(X) Of The Act & Also Made Addition Of Rs.12,80,200/- On Account Of Unexplained Income U/S 68 Of The Act. Aggrieved By The Assessment Order Dated 19.01.2024, Assessee Preferred An Appeal Before The Ld. Cit(A). The Ld. Cit(A) Vide Order Dated 25.02.2026, Dismissed The Appeal Of The Assessee.

For Appellant: Shri Randheer Kumar, CAFor Respondent: Shri Ravi Kant Chowdhary, CIT, DR

Section 250Section 50CSection 55ASection 56(2)(x)Section 68

Juris Matrix Advisors Private Limited, Mumbai vs. ITO Ward 12(3)(1), Mumbai

ITA 1831/MUM/2026[2016-17]Status: DisposedITAT Mumbai11 Sept 2026AY 2016-17

Bench: Shri Pawan Singh, Jm & Shri Arun Khodpia, Am

For Appellant: Ms. Saile Gujarathi, CAFor Respondent: Assessee by

Section 143(3)Section 145Section 28Section 43CSection 53A

Shri Ganesh Subramaniam, Chennai vs. ITO, Ncw-9(1), Chennai

In the result, the appeals of the assessee for AY 2009-10 to 2011-12 are dismissed

ITA 1942/CHNY/2025[2011-12]Status: DisposedITAT Chennai05 Aug 2026AY 2011-12

Bench: Shri George George K & Ms. Padmavathy.S

For Appellant: AYEPS5932R

Section 147Section 148Section 250Section 55A

Shri Ganesh Subramaniam, Chennai vs. ITO, Ncw-9(1), Chennai

In the result, the appeals of the assessee for AY 2009-10 to 2011-12 are dismissed

ITA 1941/CHNY/2025[2010-11]Status: DisposedITAT Chennai05 Aug 2026AY 2010-11

Bench: Shri George George K & Ms. Padmavathy.S

For Appellant: AYEPS5932R

Section 147Section 148Section 250Section 55A

Shri Ganesh Subramaniam, Chennai vs. ITO, Ncw-9(1), Chennai

In the result, the appeals of the assessee for AY 2009-10 to 2011-12 are dismissed

ITA 1940/CHNY/2025[2009-10]Status: DisposedITAT Chennai05 Aug 2026AY 2009-10

Bench: Shri George George K & Ms. Padmavathy.S

For Appellant: AYEPS5932R

Section 147Section 148Section 250Section 55A

Rakesh Bhargava, Haryana vs. Deputy Commissioner of Income Tax, Haryana

In the result, the appeal IT(IT)A No

ITITA 25/DEL/2025[2023-24]Status: DisposedITAT Delhi27 Jul 2026AY 2023-24

Bench: Sh. Vikas Awasthy & Sh. Naveen Chandrait(It)A No. 25/Del/2025 (Assessment Year : 2023-24) Mr. Rakesh Bhargava Vs. Dcit Circle 122/54, Silver Oak Complex International Taxation Dlf, Gurgaon Haryana-02 Gurgaon Haryana - 02 Pan No. Anspb 4689 F (Assessee) (Respondent) Assessee By Shri A. K. Batra, C.A. Revenue By Dr. Shalini Verma, Cit-D.R. Date Of Hearing: 07.07.2026 Date Of Pronouncement: 27.07.2026

Section 143(2)Section 143(3)Section 144CSection 144C(13)Section 54

Pallavi Rajesh Dattani, Porbandar vs. Income Tax Officer Ward 2(3), Porbandar

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

ITA 462/RJT/2026[2011-12]Status: DisposedITAT Rajkot24 Jul 2026AY 2011-12

Bench: Dr. Arjun Lal Sainiआयकरअपीलसं./Ita No. 462/Rjt/2026 ("नधा"रणवष"/Assessment Year: (2011-12) Pallavi Rajesh Dattani, Income Tax Officer, Ward 2(3), Aayakar Bhawan, Porbandar, Giriraj, Jaherpir Area, Near Dena Vs. Gujarat, 360575. Bank, Porbandar, Gujarat 360575 "ायीलेखासं./जीआइआरसं./Pan/Gir No.: Agapd0633L (अपीलाथ"/Assessee) (""यथ"/Respondent) Assessee By : Shri Sagar Shah, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 07/05/2026 : 24/07/2026 Date Of Pronouncement Order Per, Dr. Arjun Lal Saini, Am:

For Appellant: Shri Sagar Shah, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR

Section 139Section 143(3)Section 234ASection 250Section 271(1)(c)Section 50C

Ramkrishna Banerjee, Hooghly vs. ITO, Circle 23(1), Hooghly

ITA 1399/KOL/2026[2020-2021]Status: DisposedITAT Kolkata23 Jul 2026AY 2020-2021

Bench: Shri Yogesh Kumar U.S. & Shri Rakesh Mishraassessment Year: 2020-21

For Appellant: Shri Rip Das, ARFor Respondent: Shri Praveen Das Chowdhury, Sr. DR

Section 147Section 250Section 55A

Khimji Deva Daka, Vashi Navi Mumbai vs. ACIT 28(2), Mumbai, Vashi Navi Mumbai

ITA 1154/MUM/2026[2014-2015]Status: DisposedITAT Mumbai16 Jul 2026AY 2014-2015

Bench: Sandeep Gosain & Girish Agrawal

For Appellant: ADJPP2981M

Section 143(2)Section 143(3)Section 153Section 2Section 45Section 48Section 50CSection 55A

Income Tax Officer, Ward-1(2)(1), Vadodara vs. Shri Sureshnhai Padhiyar Legal Heir of Late Shri Motibhai Maganlalbhai Padhiyar, Vadodara

Appeal of the Revenue is dismissed

ITA 1119/AHD/2024[2012-13]Status: DisposedITAT Ahmedabad13 Jul 2026AY 2012-13

Bench: Different Authorities Was Not Reliable & Therefore, The Assessee Officer Has Made The Reference To The Dvo?

For Appellant: Shri Mehul K. Patel, AdvocateFor Respondent: Shri Alpesh Parma, CIT, D.R

Section 139Section 234ASection 250Section 55A

Holabasappa Doddabasappa Kalledevar, Haveri vs. Income Tax Officer, Ward-1, Haveri

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

ITA 145/BANG/2026[2019-2020]Status: DisposedITAT Bangalore06 Jul 2026AY 2019-2020

Bench: Shri Waseem Ahmed & Shri Keshav Dubeyassessment Year : 2019-20

For Appellant: Shri Chandra Shekar, Adv A.RFor Respondent: Shri Ganesh R Ghale, Standing Counsel for the Dept

Section 147Section 148Section 234ASection 250Section 54FSection 55A

Shri Kiran Dinkar Patil, Ambernath vs. Income Tax Officer, Kalyan

In the result, the appeal of the assessee bearing

ITA 3266/MUM/2026[2014-15]Status: HeardITAT Mumbai30 Jun 2026AY 2014-15

Bench: Shri Om Prakash Kant & Shri Anikesh Banerjee

For Appellant: AMCPP2959D

Section 143(3)Section 148Section 250

Prabhat Bhatia, West Patel Nagar, Delhi vs. Circle Int Tax 1(1)(2), New Delhi

In the result, appeal of the assessee is allowed

ITA 1116/DEL/2025[2015-16]Status: DisposedITAT Delhi25 Jun 2026AY 2015-16

Bench: Shri Vikas Awasthy & Smt. Renu Jauhri

Section 144Section 147Section 148Section 55A

Suresh Indermal Jain, Mumbai vs. ITO - 8(3)(1), Mumbai

In the result, the appeal of the assessee is allowed

ITA 2742/MUM/2026[2019-20]Status: DisposedITAT Mumbai24 Jun 2026AY 2019-20

Bench: Shri Om Prakash Kant () & Shri Anikesh Banerjee () Assessment Year: 2019-20

For Appellant: Shri Mukesh Thakwani (SR DR)For Respondent: Shri Suchek Anchaliya, C.A

Section 143(1)Section 147Section 148Section 148ASection 55ASection 56(2)(x)

Sarlaben M. Raj, Bharuch vs. ITO, Ward 1(4), Bharuch

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

ITA 567/SRT/2025[2011-12]Status: DisposedITAT Surat16 Jun 2026AY 2011-12

Bench: The Learned A O. The Learned Ao Had Passed Order Dismissing The Appellant Claimed Only For The Reason That The Valuation Report From The Dvo Was Not Received. 2. The Appellant Prays That The Addition Made Of Rs. 9,00,000/- Being Long-Term Capital Gain On Sale Of Residential Property Be Deleted. 3. The Appellant Craves Leave To Add, Amend Or Withdraw Any Ground Of Appeal At The Time Of Hearing."

Section 147Section 148Section 55A