https://www.taxtmi.com/caselaws?id=772856 ITAT Delhi held that capital gains from sale of land by parent company to its 100% subsidiary was exempt under section 47(iv) and wrongly offered to tax. The Tribunal rejected revenue's objection that new claims cannot be raised before ITAT without filing revised return, citing SC precedents in NTPC and Goetze cases. ITAT allowed assessee's cross-objection, directed AO to exclude capital gains from taxable income and refund excess tax paid. However, interest under section 244A was denied for the period from filing date to determination date as delay was attributable to assessee's incorrect declaration. en-us Fri, 23 May 2025 00:00:00 +0530 Thu, 12 Jun 2025 15:25:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772856 ITAT Delhi held that capital gains from sale of land by parent company to its 100% subsidiary was exempt under section 47(iv) and wrongly offered to tax. The Tribunal rejected revenue's objection that new claims cannot be raised before ITAT without filing revised return, citing SC precedents in NTPC and Goetze cases. ITAT allowed assessee's cross-objection, directed AO to exclude capital gains from taxable income and refund excess tax paid. However, interest under section 244A was denied for the period from filing date to determination date as delay was attributable to assessee's incorrect declaration. Case-Laws Income Tax Fri, 23 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772856