2025 (7) TMI 321

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....tions, the delays in re-filing and filing the captioned appeal stand condoned. 2. The applications are disposed of. ITA 192/2025 3. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 [the Act], inter alia, impugning an order dated 30.06.2023 [impugned order] passed by the learned Income Tax Appellate Tribunal [ITAT] in ITA No. 9342/Del/2019 captioned ACIT Circle-25 (2) v. Thomson Press (India) Limited, in respect of Assessment Year [AY] 2014-15 4. The Revenue had preferred the aforesaid appeal against the order dated 27.09.2019 passed by the Commissioner of Income Tax (Appeals)- 9, New Delhi [CIT(A)] whereby the Assessee's appeal against an order dated 05.12.2018 passed under Section 147 of t....

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.... The CIT(A) found that the addition of Rs. 20.00 Crores under Section 50C was not sustainable as the date on which the transaction for sale and purchase of the property in question was entered into was prior to the date of enhancement of the circle rate. It was noted that the transacting parties, that is M/s Living Media India Limited and Maccons Infra Private Limited, had entered into the registered agreement to sell on 30.05.2013 and on the same date stamp duty of Rs. 72.00 Lakhs was paid by the Maccons Infra Private Limited. 8. Undisputedly, the circle rate applicable to the property in question at the material time was Rs. 18,000/- per square meter and thus, the transaction entered into was not a value, which was below the circle rat....

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....the Revenue has projected the following questions for consideration of this Court: "A. Whether on the facts and circumstances of the case, the Hon'ble ITAT justified in deleting the addition of Rs. 20 Crores made on account of Capital Gains u/s 50C of the Act on the basis of the information received from Investigation Wing of the Income Tax Department, Noida? B. Whether on the facts and circumstances of the case, the Hon'ble ITAT is justified in giving relief to the assessee on the basis of Proviso to 50C of the I.T. Act, 1961 which was made applicable from 01.04.2017, whereas the case is related for F.Y 2013-14?" 13. It is at once clear that no substantial questions of law arise in the facts of the present case. The is....