2024 (2) TMI 1559

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....3505 & 3506 of 2024 - -<br>Income Tax<br>Honourable Mr.Justice Senthilkumar Ramamoorthy For the Petitioner : M/s.Subbaraya Aiyar Padmanabhan, Ramamani For the Respondents : Mrs.S.Premalatha, Jr. SC ORDER The petitioner assails an order issued in revision proceedings under Section 264 of the Income Tax Act, 1961 (the Income Tax Act). In financial year 2020-21, the petitioner states that....

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....regard to the long term capital gains arising on the sale of immovable property, the return was selected for scrutiny. An assessment order came to be issued thereafter on 22.12.2022 and long term capital gains was computed. In respect of said assessment order, the petitioner filed the revision petition under Section 264 of the Income Tax Act. Since such petition was rejected, the present writ peti....

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....earned junior standing counsel, accepts notice on behalf of the respondents. She submits that the sale deed discloses the consideration of Rs. 4,00,00,000/- and that the execution of an agreement, in the form of a receipt, by and between the petitioner and his agent does not shift the tax burden to such agent. She also submits that the impugned order does not warrant interference because the conte....

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....ned in the revision petition. On examining the impugned order, particularly paragraph 4 thereof, which is the operative part, I find that the officer has not dealt with this contention and recorded reasons for rejecting the same. For such reason, the impugned order calls for interference. 6. Therefore, the impugned order is quashed insofar as it relates to the computation of capital gains on th....