2020 (10) TMI 842

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e Respondent : Mr.G.Baskar JUDGMENT T. S. SIVAGNANAM, J. This appeal filed by the assessee under Section 260 A of the Income Tax Act, 1961 ('the Act' for brevity) is directed against the order dated 05.09.2019 passed by the Income Tax Appellate Tribunal, Madras, 'A' Bench ('Tribunal' for brevity), in I.T.A.No.818/Chny/2019 for the assessment year 2014-15. The appea....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e brought to tax under the heading income from other sources? 3.Is not the finding of the Tribunal bad by holding that the benefit of revised guide line value had to be given to the assessee based on a State Government guideline value which came into effect with effect from June 2017 ignoring the fact that the law as it stood on the date of purchase and the actual sale consideration paid ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... for a sale consideration of Rs. 144,00,000/- by Sale Deed dated 14.09.2013. For the purpose of Stamp Duty, the value of the documents was fixed at Rs. 168,00,000/-. After the assessment was completed by order dated 29.12.2016, the Principal Commissioner of Income Tax Appellate Tribunal-V, Chennai ('the PCAT' for brevity), invoked his power under Section 263 of the Act on the ground that t....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ssessee contended that the said provision will have no application to her case as 50% of the Sale consideration had already been paid and the assessee could not withdraw from the transaction and therefore, she should not be penalised. 4. On a reading of the order passed by the PCIT under Section 263 of the Act, dated 01.10.2018, we find that the Commissioner has not dealt with the aspects with ....