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INCOME TAX APPELLATE TRIBUNAL (CHANDIGARH BENCH)
LALIET KUMAR, J, MANOJ KUMAR AGGARWAL, AM
SH. PREM SINGH RAJA CHAMBA – Appellant
Versus
PR. C.I.T. -1 CHANDIGARH – Respondent
| Table of Content |
|---|
| 1. overview of appeals and applicability of section 263. (Para 2) |
| 2. arguments supporting the appellant's claims regarding enforceable rights. (Para 3) |
| 3. counterarguments from the revenue side indicating possible tax avoidance. (Para 4) |
| 4. court's detailed analysis on taxation and enforceable rights. (Para 5) |
| 5. conclusion quashing revised assessments issued under section 263. (Para 7 , 8) |
आदेश Order
PER LALIET KUMAR, J.M:
These two appeals by the assessee are directed against separate orders passed under section 263 of the Income Tax Act, 1961 (hereinafter referred to as "the Act") by the PCIT, Chandigarh-1, dated 20.03.2024 and 17.03.2022 for the assessment years 2015–16 and 2017–18 respectively. Since common issues are involved and facts are interlinked, both appeals are being disposed of by this consolidated order.
2. Briefly the facts of the case are that the assessee is an individual who entered into agreements to sell immovable properties in both assessment years under appeal. The original agreements were executed with M/s Hemali Resorts Pvt. Ltd., who subsequently assigned its rights to M/s APG Intelli Homes Pvt. Ltd., in whose favour the final registered sale de
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