Category: Income-Tax Act

Archive for the ‘Income-Tax Act’ Category


D. Vijayalakshmi. (Mrs.) v. ITO (2023) 199 ITD 797 (Chennai) (Trib.)

S. 54F : Capital gains-Investment in a residential house-Purchase of land-Using advance received with respect to sale of property-Deduction cannot be denied merely because sale deed for sold out property was executed beyond period of a year.[S. 45]

Surendra Babu Sabbineni. v. DCIT (2023) 199 ITD 544/ 222 TTJ 206/ 223 DTR 153 (Hyd) (Trib.)

S.54F : Capital gains-Investment in a residential house-More than one residential property on date of transfer of capital asset-Not entitle to deduction.[S. 45]

MHM Holding (P.) Ltd. v. ACIT (2023) 199 ITD 265 (Bang) (Trib.)

S. 50B : Capital gains-Slump sale-Failure to examine evidence-Matter remanded.[S. 2(42C)]

ITO v. Brizeal Realtors and Developers LLP. (2023) 199 ITD 208 (Mum) (Trib.)

S. 47(xiiib) : capital gains-Transaction not regarded as transfer-Capital gains-Conversion of firm in to LLP-Good will-Books of account of predecessor company did not include goodwill in accumulated profits, there was no violation of clauses (c) and (f) of section 47(xiiib) and additions made under section 45 treating assessee to be in violation of clauses (c) and (f) of section 47 could not be sustained.[S. 45]

ACIT v. Sarojini B. Nair. (Smt.) (2023) 199 ITD 538 (Chennai) (Trib.)

S. 45(2) : Capital gains-Conversion of a capital asset in to stock-in-trade-Land converted into stock-in trade-Earmarked land for road and other common amenities purpose in terms of municipal regulations-No transfer-Neither capital gains nor business profits.[S. 45, 47 (iii)]

Sobhi Lal Saini. v. ACIT (2023) 199 ITD 794 (Delhi) (Trib.)

S. 45 : Capital gains-Land situated within jurisdiction of municipality and population was more than 10,000-Not an agricultural land-Sale proceed out of compulsory acquisition of land was not exempt under section 10(37). [S. 2(14)(iii)(a), 10 (37), Land Acquisition Act, 1894 ]

Bhagvat Singh. v. ITO (2023) 199 ITD 108 (Delhi) (Trib.)

S. 45 : Capital gains-Agreement to sale of agricultural land-Capital asset-Subsequently the land use was changed as non agricultural land-Possession was given when the sale deed is executed-Relevant date is execution of sale deed-Liable to capital gains.[S. 2(14), 2(47) 47, 50C]

ACIT v. Pravin Mnailal Sanghvi. (2023) 199 ITD 534 (Pune) (Trib.)

S. 45 : Capital gains-Land sold after a gap of 13 years-Assessable as capital gains and not as business income-Cost of acquisition-Matter remanded. [S.28(i), 55]

ACIT v. Shree Ami Office Owner’s Association. (2023) 199 ITD 670 (Ahd) (Trib.)

S. 45 : Capital gains-Agreement for sale-Conveyance was made on 22-5-2007-Capital gains taxable in the assessment year 2008-09.[S. 2(31)(v), 2(47)(v)]

ACIT v. Shree Ami Office Owner’s Association. (2023) 199 ITD 670 (Ahd) (Trib.)

S. 45 : Capital gains-Business income-Mere fact that assessee-AOP purchased and made construction thereon itself would not be sufficient to hold that income earned on such sale of property would qualify as business income and same would be taxable as capital gains. [S. 2(31)(v), 28(i)]