IN THE INCOME TAX APPELLATE TRIBUNAL “D” BENCH, KOLKATA BEFORE SHRI RAJESH KUMAR, AM AND SHRI PRADIP KUMAR CHOUBEY, JM (Assessment Year:2016-17)

ITO, Ward 59(3)

Ramautar Saraf (HUF)

Income Tax Office, Uttarapan BF-256, Block-BF, Salt Lake, Complex, DS-IV, Manicktala Civil Bidhan Nagar, Kolkata-700064 Vs.

Centre, Kolkata-700067, West Bengal West Bengal (Appellant) (

Respondent)

PAN No. AADHR1153A Assessee by : Shri S.K. Tulsian &

Ms. Puja Somani, ARs Revenue by : Shri S.B. Chakraborthy, DR Date of hearing: 06.01.2026 Date of pronouncement: 20.01.2026

O R D E R

Per Rajesh Kumar, AM:

This is an appeal preferred by the assessee against the order of the National Faceless Appeal Centre, Delhi (hereinafter referred to as the “Ld. CIT(A)”] dated 09.09.2025 for the AY 2016-17.

2. The assessee has raised following grounds of appeal:-

“1. That, on the facts and circumstances of the case, the Ld. CIT(A), NFAC, Delhi erred in law in having upheld the disallowance of deduction of Rs.2,86,42,500/- on the alleged ground of the appellant's failure to meet the statutory conditions of sec. 54 of the Act when it has been established by filing evidence that the capital gains on transfer had been invested in the c