2026 (6) TMI 856

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....Year 2021-22. 2. The Assessee has raised the following grounds of appeal: "1. The order of the Commissioner of Income-tax (Appeals) is contrary to the law, facts and circumstances of the case. 2. The CIT (Appeals) erred in rejecting the several objections raised in the Grounds of the Appeal to the Total income determined and the status in which the assessment has been made (in so far as the addition as LTCG income is concerned) and dismissing the appeal. 3. The impugned order Under Section 250 of the Act, passed by the First Respondent is totally illegal, arbitrary, violative of principles of natural justice, vitiated by prejudged and pre-determined approach, malice in law and in fact and therefore liable to be....

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....12.02.2021 Rs. 84,54,440 and Rs. 21,13,610, in total Rs. 1,05,68,050, after deducting Tax Deducted at Source (TDS) through NEFT /Government of Tamilnadu. 11. The appellant submits that he submitted his return of income in ITR 3-Detailed ITR FORM for the assessment year 2021-22 on 02.01.2022 under section 139(1) of the Income-tax Act, i.e filed within the stipulated time as per the ACT and admitted a total income of Rs. 4,01,880/- along with detailed Long term capital gain workings with his investments under section 54EC of the ACT. (It is available in Page 36 & 37 of the above said ITR Form) 12. The appellant submits that the CPC, Bengaluru, while processing the return of income under section 143(1) of the ACT, on....

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....llant has correctly mentioned the facts of my case, re-investment particulars and the details of rectification order passed under section 154 of the act by the CPC Bengaluru. 18. The appellant submits that again on 01.11.2023 made another e-response vide ack.no.498364661011123 to the respondent stated that the highest judicial forums has considered the re-investments made in the Government of bonds as per the provisions of Section 54EC of the 70 SH ACT, ACT, and a quoted various case laws, including the Hon'ble Jurisdictional Madras High Court case law. 19. In the meantime, my father Mr. B.J Fernandez was expired on 08.08.2025 and the respondent has passed the Impugned order on 07.10.2025. It is also against the rule o....

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....ppellant moved a petition u/s. 154 of the Act on 22.08.2022 which was rejected by CPC. 4. Being aggrieved by the order u/s. 154 of the Act, an appeal was filed before the ld.CIT(A) who vide impugned order dismissed the appeal by holding that the specified investments u/s. 54EC was not made within the time limit prescribed u/s. 54EC of the Income Tax Act, 1961. 5. Being aggrieved, the appellant is in appeal before us in the present appeal. The learned Counsel submits that during the previous year relevant to assessment year under consideration, the Government of Tamilnadu acquired 7200 sq.ft of land belonging to the appellant for the purpose of setting up of industrial estate under SIPCOT at Sriperumbudur received compensation of Rs. 1....