TaxTMI 
TaxTMI 
TaxTMI 
2014 (5) TMI 1032
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....ical grounds have been raised by the assessee which are as under : 1. That the learned Commissioner of Income-tax (Appeals), Ludhiana has erred in upholding the action of the Assessing Officer in assessing the long-term capital gain at Rs. 24,47,500. 2. That the learned Commissioner of Income-tax (Appeals) has erred in upholding in not giving the benefit of exemption under section 54B for the purchase of Agricultural land in the name of his son as per binding judgment of the hon'ble Punjab and Haryana High Court. 3. That the worthy Commissioner of Income....
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....High Court in the case of CIT v. Gurnam Singh [2010] 327 ITR 278 (P&H) but the Assessing Officer observed that that the decision was distinguishable on facts and ultimately computed capital gain without allowing deduction under section 54B of the Act. 4. On appeal it was mainly contended that the assessee was aged 75 years. The land which was sold was in the joint name of the assessee and his son. Because of old age of the assessee, new land purchased was registered in the name of his son, who was the only son of the assessee. Reliance was again placed on the decision of CIT v. Gurnam Singh [2010] 327 ITR 278 (P&H). Reliance was also placed on the Delhi Bench of the Tribunal in the case of Jagpal Singh v. ITO [2010] 186 Taxman 26 (Delhi) (....
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....nder: " I, Bant Singh son of Shri Harnam Singh resident of Village Bha mian Khurd, Ludhiana do hereby solemnly affirm and declare as under : 1. That I am presently aged about 75 years. 2. That I am enclosing herewith proof to confirm my age. 3. That I have only son namely Shri Nirmal Singh. 4. That I have only agricultural income and no other business income. 5. That my son is living with me h....