2025 (5) TMI 1955

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....he Appellant : Sh. Himanshu Sharma, CA For the Respondent : Shri A. S. Rana, Sr. DR ORDER PER AVDHESH KUMAR MISHRA, AM These appeals of the assessee for Assessment Year (hereinafter, the 'AY') 2017-18 are directed against orders dated 11.12.2023 of the Commissioner of Income Tax (Appeals), NFAC, New Delhi [hereinafter 'the CIT(A)']. 2. These appeals contain common facts and ground; ....

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....ompleted at income of Rs. 10,55,110/- During the relevant year, the assessee had received land compensation of Rs. 56,89,111/- along with interest of Rs. 3,55,111/- thereon from NHAI. Considering the land compensation along with interest thereon as exempted income, the assessee did not offer the same for tax. The said land compensation was held exempted by the Assessing Officer (AO). However, the ....

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....to the penalty under section 270A of the Act, the Ld. Authorized Representative (AR) contended that there were contradictory decisions on the issue of taxability of interest on land compensation received from the Government and Government Authorities. Keeping in view various decisions of the Hon'ble Courts and Tribunal, the assessee, in bonafide belief, claimed the land compensation along with int....

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....r a technical default. There was no malafide in the said transaction. It was not a case of tax avoidance. The father has handed over the cash to his son (assessee) due to the demonetization. The Ld. AR thus, prayed for relief as there was genuine hardship and reason for advancing the sum to the assessee. 7. On the other hand, the Ld. Sr. DR supported orders of lower authorities. 8. We have h....