Ajay Parasmal Kothari v. ITO ( Mum)( Trib) www.itatonline .org

S. 4 : Charge of income-tax – Re development of building – Monthly rental compensation received from the builder for rent of alternative accommodation – Not utilised for paying alternative accommodation – Capital receipt – Not taxable as income from other sources – Delay of 1566 days in filing the appeal is condoned . [ S. 56, 254(1) ]

The Tribunal condoned the delay of 1566 days in filing of the appeal by the assessee . The assessee received  from the builder monthly rent as compensation for providing alternative accommodation  as the building has gone for redevelopment . The  Assessing Officer treated the said amount as income from other sources . The  addition was affirmed by the CIT(A) .  On appeal  it was  contended that the amount  received by the builder is in the nature of hardship compensation and it is a capital receipt hence taxable .    The Revenue argued that the aassessee has not utilised the rent received for his accommodation  and he has lived with his parents . Tribunal deleted the   addition on the ground that the receipt of compensation for hardship is in the nature of capital receipt hence not taxable . Followed  Deliah Raj Mansukhani ( Smt) v. ITO ( ITA No. 3526/Mum/ 2017 dt. 29-1 -2021  ( ITA No. 2823/Mum/ 2022 dt. 3-4 -2023 )( AY. 2013 -14 )  

 

One comment on “Ajay Parasmal Kothari v. ITO ( Mum)( Trib) www.itatonline .org
  1. GOPALRATHNAM PRABHAKAR says:

    Yes it is rightly decided by Honrable ITAT that rent paid by he builder duing the construcion period to the owne is not an income as no service is rendered nor it is a casual income. It is only for the alternatrive accommodation which the builder did not provide hence the compensation. If the buildedr provided alternative accommodatrion whether the assessing officer would haved viewed as an inocme