TaxTMI 
TaxTMI 
2026 (2) TMI 869
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....and other sources, filed return of income on 16.10.2016 declaring income of Rs. 21,63,53,810. The return was processed under Section 143(1) of the Act. The case was selected for scrutiny assessment through CASS for limited scrutiny based on following reasons: 1. "Substantial increase in capital in a year". 2. "Large deduction claimed u/s. 54B, 54C, 54D, 54G, 54GA". 3. "Large long term capital gain". 3. Notice under Section 143(2) of the Act dated 22.06.2016 was served on assessee. Subsequently, notices under Section 142(1) dated 10.07.2018 and 06.09.2018 were served on assessee. In response to notices under Section 143(2) and 142(1) of the Act, Learned Authorised Representative of assessee made submissions through e-assessment module. On completion of assessment proceedings, Ld. AO vide order dated 30.12.2018 made addition of Rs. 41,71,72,652/-. Against order dated 30.12.2018 of Ld. AO, assessee filed appeal before Ld. CIT(A) which was allowed vide order dated 25.08.2023. 4. Being aggrieved, the appellant/revenue preferred present appeal. 5. Learned Authorized Representative for the Revenue submitted that Ld.CIT(A) failed to consider that the add....
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....did not use the land for agricultural purposes two years immediately preceding the date on which the sale took place. Though, the Revisional Authority while rejecting the revision under Section 264, has stated so, perusal of the order passed by the Assessing Officer would show that he was carried over by the fact that the land was sold to a person, who is a developer and therefore, the petitioner is not entitled to benefit under Section 54B. Apart from saying so, the Assessing Officer has given a finding that the assessee could not show that there has been an agricultural activity. The first respondent has also reiterated the very same contention. On the other hand, it is stated by the petitioner that he has produced chitta, adangal etc., for the relevant period in support of his contention that the subject matter land were used for agricultural purposes two years immediately preceding the date on which the transfer took place. Therefore, this Court is of the view that the factual aspects raised in this writ petition, need to be considered once again by the first respondent and to decide the matter as to whether the petitioner has satisfied the requirement contemplated und....
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....he properties by the Inspectors of the A.O further revealed that marriage ceremonies and film shootings were being carried out at the farm houses purchased from Ms./s Latika Dutt and Charu Dutt whereas the property purchased from Sh. Mahesh Aggarwal was being used as a godown for business purposes and was sealed for violations. The A.O. recorded the statement of the assessee u/s. 131 wherein it was stated by him that the lands were being used for agricultural purposes. In view of the findings, the Ld. A.O. disallowed the deduction of Rs. 41,71,72,652/- to the appellant and added the same to his income vide order u/s. 143(3) dated 31/12/2018. During the appellate stage, additional evidence under Rule 46A was filed by the appellant before my predecessor on 21/08/2019. The appellant has submitted the following additional evidences to support his contentions: 1. Copy of order u/s. 81 of Revenue Department sold during the year 2. Google Earth Pictures of the property sold during the year 3. Tube Well Sanction of the Property sold during the year under appeal 4. Khasra/Gidawari of Assessee after Purchase 5. Website snapshot of SDMC ....
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....er within a period of three years of its purchase, the cost shall be reduced, by the amount of the capital gain." From a plain reading of the above, It is clear that to claim the benefit of this provision, the following conditions are required to be satisfied:- (i) the capital gain arises from the transfer of land which, in the two years immediately preceding the date on which the transfer took place, was being used by the assessee or his parent for agricultural purposes; and (ii) the assessee has purchased the land within a period of two years after the sale of the above land for being used for agricultural purposes. The Ld. A.O has disputed the use of the land for agricultural_purposes and hence disallowed the deduction u/s. 54B. It is important to mention that land classifications in Delhi are done by DDA as per its master plan. The three lands under consideration have been classified as Agricultural by the DDA in its master plan. The same is mentioned in the respective Sale Deeds as Agricultural Land. Further land records of the Delhi Govt such as Khasra/Gidawari as submitted show that cultivation/agricultural activity has been taking place o....
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....hy vs. Principal Commissioner of Income-tax, Chennai reported in (2020) 113 taxmann.com 341 (Madras) has held as under- "Where the A.O rejected assessee's claim for deduction under section 54B in respect of capital gain arising from sale of agricultural land on ground that purchaser of land was a builder and thus, sald piece of land was not agricultural land, since view taken by Assessing Officer while rejecting assessee's claim was not in consonance with requirements made under section 54B, Impugned order passed by him was to be set aside." Hence, once conditions for section 54B are satisfied, the other contentions like land being utilized for non-agricultural purposes are totally irrelevant considerations. In view of the facts and circumstances narrated above, the appellant is eligible for deduction u/s. 54B. The disallowance made by the A.O is hereby deleted. Ground Nos 1 to 6 are hereby allowed. Grounds nos 7 & 8 Since, ample opportunity has bee opportunity has been granted to the appellant, the grounds raised in Ground No 7 and 8 are herewith addressed. Hence, this ground stands allowed. Ground no 9 The iss....
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....rd that Ld. AO disputed the use of land for agriculture purpose and disallowed deduction under Section 54B of the Act. Ld. AO had considered: a) Sale deed pertaining to land sold by assessee and sale deeds of land purchased from Ms. Latika Dutt (pages 137 to 150 of the paper book), Ms. Charu Dutt (pages 151 - 169 of the paper books ) and Mr. Mahesh Aggarwal (pages 170-178 of the paper books); (b) ITRs of assessee mentioning agricultural income; (c) DDA land searched on public domain; and (d) verification by team of inspectors. 10. However, Ld. CIT(A) found that the three sale deeds of lands purchased by assessee mentioned as land agriculture. He further observed that the land purchased by assessee was classified agriculture by DDA in its Master Plan. As per RTI Replies, pages 202 & 203 of paper book Master Plan of DDA has not being notified. The DDA's Master Plan is not in paper books. It is a material fact established on record that three sale deeds of the land purchased by the assessee from Ms. Latika Dutt, Ms. Charu Dutt and Mr. Mahesh Aggarwal mention the land as "agriculture land". Land records of Delhi Government as such Khasra girdawari....
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....f property 4,22,360/- 99,95,77,640/- Less Indexed Cost 1,31,77,336/- Balance 98,64,00,304/- Deduction u/s. 54B 78,54,42,491/- Deduction u/s, 54EC 50,00,000/- 79,04,42,491/- Capital Gains. 19,59,57,813/- 3.1. Further, the AO noted that the assessee had purchased three properties as per details below for a sum of Rs. 38,97,99,000/- and offered capital gains amounting to Rs. 19,59,57,813/- for taxation as per the above computation. I. From Latika Dutt: Purchase of land property on 03/10/2016 from Latika Dutt of 12 Bigha 14 Biswa bearing Khasra Nos. 298/1 (7-0) 298 MIN (2-09), 1820/297 MIN EAST (2-11) and 1819/297 MIN WEST (0-14) in Asola Tehsil Saket, New Delhi 110074 for a consideration of Rs. 25,26,74,000/- (excluding stamp duty and registration charges) on 03.10.2016. II. From Charu Dutt: Purchase of land on 04/01/2017 from Charu Dutt amounting to Rs. 13,56,25,000/- (excluding stamp duty and registration charges) of 13 Bigha 5 Biswas bearing Khasra Nos. 1820/297 Min West(1-8),1819/297 MIN WEST (0-8), 261, 261, 263, 260, 259. 267 etc village Asola, New Delhi 110074. III. From Mahesh Aggarwal: Purchase of lan....
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....dated 28.12.2018, who visited the above sites. The said report of the Inspectors forming part as Annexure-A of the assessment order is reproduced as under:- Annexure A To, The Asst. Commissioner of Income Tax, Circle-53(1), New Delhi Madam, Sub: Inspector's report in respect of inquiry conducted as per directions, in the case of Bhopinder Singh Bhalla, PAN: AEIPM8618M, for the A.Y. 2016-17 ... reg. 1. As directed by your good self, I along with Inspector Saurabh Kumar Maurya visited for field Inspection of properties situated al Asola and Bhati Village for which Deduction u/s. 54B of the Income Tax Act. 1961 was claimed by the assessee. (a) Bearing Khasra No. 298/1Etc., Village- Asola, New Delhi-110074 (b) Bearing Khasra No. 1820/297 Min West Village- Asola, New Delhi-110074 (Both the above named property are known as! demarcated as Plot No. A-3, Asola, Near Shanidham Mandir, New Delhi-110074) The following observations were made: 1. On enquiry from the Patwari of the SDM Saket office, the map of the abovementioned Khasra Numbers was provided by the Patwari. The patwari and inf....
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....k is over which will be completed in a month or two and also after getting due approval from the competent authority. 3. So, it is clear proof/ evidence that no agriculture activity was carried out on the said premises. The intention of the owner for letting out of these premises for marriage and other commercial purposes clearly shows the nature of land usage of these premises which is clearly for non- agricultural purposes. As directed, we also visited Khasra No. 2004/1461 Min etc. Village Bhati, New Delhi-110074( known as part of Hillview Greens, Mahabalipuram, Chhoti Bhati, New Delhi-110074 plotting done by Sh. Mahesh Aggarwal) and the following observations were made :- 1. We made an inquiry from the property dealer situated near the above mentioned premises and also made inquiry from the locals residing near the said property and identified the same. There was a huge tin structure erected with two shutters and one security guard room. One of the locals apprised me that the said property was scaled by the Competent Authority due to commercial activity ( Timber and plywood work) carried out therein by the owner of the premises. We took the photos and ....
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....act the land purchased was being used for commercial purposes, the AO held that the deduction of Rs. 41,71,72,652/- [Deduction u/s. 54B of Rs. 78,54,42,491/- as claimed by assessee minus unutilized amount of Rs. 36,82,69,839/- in Capital gains account on which tax is pad during AY 2018-19] claimed by the assessee on purchase of land doesn't fall within the ambit of Sec. 54B of the Act and the same was brought to tax accordingly under section 45 of the Act. 4. Aggrieved with the said order, the assessee filed an appeal before the Ld. CIT(A), who allowed the appeal of the assessee and the Department is in appeal before us by raising grounds of appeal:- "Whether on facts and circumstances of the case, the Ld.CIT(NFAC) has not considered the addition of Rs. 41,71,72,652/- on account of the deduction of Rs. 41,71,72,652/- [Deduction u/s. 54B of Rs. 78,54,42,491/- as claimed by the assessee minus unutilized amount of Rs. 36,82,69,839/- in Capital Gains account on which tax is paid during AY 2018-19] claimed by the assessee on purchase of land does not fall within the ambit of Section 54 of the IT Act, 1961 without considering the basic facts of the case." 5. The relevant e....
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....ntenable." 6. My Ld. Brother has inter alia relied upon the fact that the three sale deeds of the land purchased by the assessee from Ms. Latika Dutt, Ms. Charu Dutt and Mr. Mahesh Aggarwal mention the land as "agriculture land", Land records of Delhi Government as such Khasra girdawari at page nos. 179 to 190 of paper books state land as agricultural under cultivation and that Section 81 Order of Revenue Department in case of Ms. Latika Dutt at page nos. 191-193 of the paper book, mention land use for agriculture purposes. Further, my ld. Brother also noted that the assessee submitted, tube well plan, sale bills and bills of agriculture etc. and the Ld. CIT(A) accepted additional evidence at page nos. 281 to 282 of paper books and asked the Ld. AO to verify which were not controverted. In view of these facts, my ld. Brother upheld the order of the Ld. CIT(A) and dismissed the appeal of the Revenue. 7. For analyzing the issue regarding the claim of the assessee on deduction u/s. 54B of the Act, the relevant provision of section 54B(1) is reproduced as under:- "Capital gain on transfer of land used for agricultural purposes not to be charged in certain cases. ....
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....etween 1989 to 1993. It is reasonable to expect that on such a huge tract of land over this period, there should have been substantial agricultural income if the land was being used for agricultural purposes in its true sense and not as a token activity as has been done by the assessee. These facts show the unreasonableness of the claim of the assessee that the land sold was being used for agricultural purposes over the period of its purchase and also in AY 2014-15 and 2015-16 two years prior to the date of sale in AY 2016-17. The deduction u/s. 54B of the Act is for a land which is used for agricultural purposes which will result in earning agricultural income by the assessee and to earn the agricultural income, the assessee has to use the land for agricultural purposes. It has to be borne in mind that the deduction u/s. 54B of the Act is given for the sale/purchase of 'land being used for agricultural purposes' and not for a 'land for agricultural purposes'. The evidences submitted by the assessee by way of purchase agreements categorizing the said lands as agricultural, tube well connection on the said land and electricity connection on the said land at best supports the claim o....
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....assessee's rate of return on its capital invested for the purchase of the said land by way of the agricultural income shown in AY 2014-15 and 2015-16 (prior to sale by the assessee) and 2017-18 and 2018-19 (post purchase by the assessee) was very negligible. On perusal of the sale deeds of the various properties purchased by the assessee between 1989 to 1993 (placed at page no.68-136 of the paper book) the total cost of purchase amounts to Rs. 25,70,000/- (the cumulative value of the land as available on page no. 68, 73, 77, 81, 86, 91, 95, 103 (except of the property- which is the exchange deed of property placed at page no.135-136 of the paper book, where the agreement or the agreement or the exchange value is not mentioned).On the said investment value of Rs. 25,70,000/- (which in real value terms will be much higher during the period 1989 to 1993 than in AY 2014-15 to AY 2018-19 the material period for claiming deduction u/s. 54B in this case) the agricultural income of Rs. 50,628/- and Rs. 25,500/- for AY 2014-15 and 2015-16 comes to 1.96% and 0.99% respectively. Similarly, the agricultural income of Rs. 3,28,000/- and Rs. 4,43,188/- for AYs 2017-18 and 2018-19 respectively, c....
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....epartment), on the said capital gains of Rs. 41,71,72,652/-, which again in my humble opinion, cannot be allowed merely by a symbolic or token activity of using the said land for agriculture purposes by the assessee as discussed above. 7.5. Further, the assessee in support of his claim that the land was being used for agricultural purposes, the assessee has submitted the Khasra/Girdawri of the land sold and the land purchased by the assessee on the following page nos. of the paper book as under-: Sl. No. Particulars Page No. 1 Copy of the sale deed of the property sold during the year under appeal 13-21 2 Khasra/Girdawri of Latika Dutt before purchase 179-181 3 Khasra/Girdawri of Assessee after purchase (Latika Dutt & Charu Dutt) 182 & 194 4 Khasra/Girdawri of Charu Dutt before purchase 183-187 5 Khasra/Girdawri of Mahesh Aggarwal before purchase 188-190 6 Khasra/Girdawri of Assessee after purchase 194 7.6. The same has been carefully perused. However, on its perusal, it appears that the same has been issued for all the years around the same time without any serial number and whether the due process for issuing th....
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....and as per the conditions laid down in the said section. The order in the case of the assessee passed in January, 2006 relates to AY 2006-07and is not for the AY 2014-15 and 2015-16, which are the relevant years for the determination of the land being used for agricultural purposes for determining the deduction u/s. 54B of the Act as claimed by the assessee. Even though the second order dated 07.09.2015 in the case of Ms. Latika Dutt is just prior to the date of purchase of the land by the assessee on 07.12.2015 but in view of the reasons given by me earlier in this order in para no.7 to 7.4 the findings in the said two orders u/s. 81 of the DLR Act cannot be relied upon for allowing deduction u/s. 54B of the Act as claimed by the assessee. 7.12. Therefore, in the given facts of the case and as per above discussion particularly in para no.7 to 7.4, 7.6 and 7.11 of my order, it is held that the land which has been sold by the assessee during the year and land purchased by the assessee from Ms. Latika Dutt, Ms. Charu Dutt and Shri Mahesh Aggarwal have not been used for agricultural purposes as per the requirement of section 54B of the Act to make the assessee eligible for claiming....
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....(1-8), 1819/297 MIN WEST (0-8), 261, 261, 263, 260, 259. 267 etc village Asola, New Delhi 110074. From Mahesh Aggarwal : Purchase of land on 26/12/2016 from Mahesh Aggarwal amounting to Rs. 15 Lakh of 9 Biswas bearing Khasra No.2004/1461 Etc. village Bhati, New Delhi 110074. 3. The balance unutilized amount on which the assessee paid tax is Rs. 36,82,69,839/-. In net effect, the assessee claimed deduction of Rs. 41,71,72,652/- under Section 54B of the Act after purchasing above three properties (which is now in dispute). The Assessing Officer, while framing assessment, examined the conditions as prescribed under the provisions of Section 54B of the Act for allowing deduction under this provision and, according to him, the land sold by the assessee i.e., agricultural land of area 37 Bighas 15 Biswas in Village Asola, New Delhi, is not used for agricultural purposes and, in fact, land has been purchased in 1988 and is being used for commercial purposes. This fact is noted by the Assessing Officer at page 14 of his order, which reads as under:- Condition Whether fulfilled Remarks 1 capital gain arises from the transfer of a capital asset b....
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.... by the assessee from Ms. Latika Dutt, Ms. Charu Dutt and Mr. Mahesh Aggarwal. Learned Counsel pointed out that in all the three sale deeds of the land sold &purchased by the assessee, it is clearly mentioned that the land is agricultural land. This fact is neither disputed by the learned Accountant Member, rather, he noted this fact in his order at pages 23 & 24 paragraph 7.2, and the relevant fact noted is being reproduced for the sake of brevity as, "The evidences submitted by the assessee by way of purchase agreements categorizing the said lands as agricultural, tube well connection on the said land and electricity connection on the said land at best supports the claim of the assessee that the land was agricultural land but it does not establish the claim of the assessee that the land was being used for agricultural purposes". Learned Accountant Member, however, has noted that the above documents do not support or establish the claim of the assessee that land was being used for agricultural purposes. Learned Counsel for the assessee Dr. Rakesh Gupta pointed out from the assessment order Paragraph 4 at pages 6 & 7, wherein the summary of the agricultural income declared by the a....
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.... under Section 81 dated 7th September, 2015, which is reproduced in the order of learned Accountant Member at paragraph 7.9. Learned Counsel for the assessee specifically drew my attention to the finding of fact recorded by the Deputy Commissioner/Collector (South) Saket, and the same is being reproduced again for the sake of brevity and clarity, as under:- "Case was called on various dates and finally on 07.09.2015. Both the parties were present. The respondent agreed to condone the delay in filing of appeal by the appellant. Accordingly, after hearing both the parties and in the interest of justice, the delay in filing of appeal was condoned. Further the case was heard on merit. It was contended by the Goan Sabha that there were two reports presented by the Halqa Patwari in Court of Revenue Assistant at different points of time in which dimension/area covered by Kothi in suit land is different. In one report of 2005, it is 10 biswa while in 2013 report, it is 6 biswa. This fact was claimed by this Court by seeking fresh report from Tehsildar regarding the suit land. The report of the Tehsildar is similar to the report given by Halqa Patwari in Court of Revenue Assistant ....
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....of agriculture use. As far as the orders passed under Delhi Land Revenue Act by Sub-Divisional Magistrate, Kalkaji District and Deputy Commissioner/Collector (South) Saket, he stated that it is not the determining factor for the claim of deduction under Section 54B of the Act. Learned CIT-DR also relied on the findings of Report submitted by the two Inspectors dated 28th December, 2018, wherein it is categorically admitted by the Manager of the property regarding renting out the above said premises for marriage purposes and this fact is also confirmed by the owner. Learned CIT-DR relied on the Inspectors' report. 10. In reply, learned Counsel for the assessee, apart from other arguments, confronted the Revenue on Inspectors' report and stated that the very language of the report clearly says that the Inspectors have gone as ordinary persons and this is not the report of the Inspectors, may be it is a discreet inquiry. It is clear from paragraph 2 of the report, which is reproduced by the learned Accountant Member at page 17 and 18 as Annexure 'A'. The relevant portion of paragraph 2 highlighted by the learned Counsel for the assessee reads as under:- "2. Sh. Dharmender,....
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....ed to find out if the land in a particular case is agricultural or not and some of them are (i) classification and assessment of land to land revenue, (ii) whether agricultural operations are carried on, (iii) intention of the owner, a temporary user of the land either for agricultural or non-agricultural purposes is not important but the real intention of the owner is to be ascertained, and (iv) character of adjoining land. If the surrounding lands are agricultural lands, the presumption would be in favour of holding that the land in question was also agricultural land. Once the assessee establishes that the land in question was assessed to land revenue and was continuously used for agricultural purposes, a prima-facie presumption arises from such user is that the land in question continued to be agricultural land. The price paid or received and/or the situation of the particular land in a well-developed area do not displace that presumption. The presumption can be rebutted only by showing that the land was not agricultural land and the current user of the land was a stop-gap arrangement pending some other user. Even the effect of the amendment i.e., amendment in Section 47(viii) ....
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....15. In view of the above facts and discussions carried out, the character of this land, as on the date of transfer i.e., 7th December, 2015, is agricultural land and the revenue records also prove that the agricultural land was put to use. Moreover, this has another support that the assessee is consistently declaring agricultural income and the quantum of agricultural income cannot the reason for disallowing the claim of deduction under Section 54B of the Act. The assessee is able to prove that the nature of land is agricultural and it is being used for agricultural activity as per records. The Revenue has not discharged the onus of disproving the same. 16. The lands purchased by the assessee from Ms. Latika Dutt on 3rd October, 2016, from Ms. Charu Dutt on 4th January, 2017 and from Shri Mahesh Aggarwal on 26th December, 2016, in the given facts and circumstances and discussion carried out above, the character of these lands purchased as per revenue records, sale deed, etc., is agricultural land. The revenue records i.e., Girdawri of the land clearly states that there was agricultural produce and land was put to agricultural activity. Clearly, the assessee, in assessment year 2....
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....se and wrote a separate order allowed ground of appeal of the Revenue. On account of difference of opinion between the Members constituting the Bench, a reference was made to the Hon'ble President ITAT u/s. 255(4) of the Act. The Hon'ble President vide order dated 18.07.2025 nominated Third Member to decide the reference. The ld. Third Member vide order dated 04.02.2026 concurred with the view of Judicial Member. Consequent to the opinion of Third Member, appeal of the revenue is dismissed. Order pronounced in the open court on 13th of February, 2026. ============= Document 1 ORDER The Hals Patwan of the vill Porwerl In 635 Mint Min 612 Min # 633 . santes Fatcats and . 624 625. 626, 627Min .. 628, 629 ..... is grown ---- NARO9H PAL (io (SOUTH) -1.2. NOAO. SAKET, NEW 1.TẠI Document 2 I have heard both the parties at length and gone through the documents filed by the parties. On going through the papers available on Slu nad the materials available on the records it is clear that there is not any misuse of ugriculture land. Therefore | Rajcoder Prasad, Sub-Divisional Magistrate/Revenue Assistani having the local jurisdiction over the land, hereby ord....
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.... this case. 6. That the Ld. Trial Court is biased and has shown undue favour to the respondent, 7. That the suit land is still being used for non-agricultural purpose and the order of the Ld. Trial Court for withdrawal of the notice is wrong and hence void. Case was called on various dates and finally on 07.09.2015. Both the parties were present. The respondent agreed to condone the delay in filing of appeal by the appellant. Accordingly, after hearing both the parties and in the interest of justice, the delay in filing of appeal was condoned. Further the case was heard on merit. It was contended by the Goan Sabha that there were two reports presented by the Halqa Patwari in Court of Revenue Assistant at different points of time in which dimension/area covered by Kothi in suit land is different. In one report of 2005, it is 10 biswa while in 2013 report, it is 6 biswa. This fact was clarified by this Court by seeking fresh report from Tehsildar regarding the suit land. The report of the Tehsildar is similar to the report glueBaby Halqa Patwari in Court of Revenue Assistant in 2013 on OUTH) + 890012. ...... 3 3700 * NE Certified Copy Reader to Collect 1 EW....