2022 (9) TMI 919

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....see's appeal for A.Y. 2014-15 is directed against the CIT(A) - 8, Pune's order dated 03/01/2018 passed in case No. PN/CIT(A) -8/ ITO, Wd. 12(2)/253/2017-18/596 involving proceeding u/s. 143(3) of the Income Tax Act, 1961 ; in short "the Act". Heard both the parties. Case file perused. 2. It emerges at the outset that the assessee's sole substantive ground challenging section 56(2)(vii)(b) ad....

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....nd foremost issue that arises for our apt adjudication in this backdrop herein is as whether such leasehold rights are covered under the statutory definition of "any immovable property" u/s.56 (2)(vii)(b) as defined in Explanation (d)(i) as "being land or building or both." We note that the legislature has used an identical expression in section 50C(1) of the Act wherein various judicial precedent....