IN THE INCOME TAX APPELLATE TRIBUNAL ‘A’ BENCH, BANGALORE BEFORE SHRI WASEEM AHMED, ACCOUNTANT MEMBER AND SHRI SOUNDARARAJAN K, JUDICIAL MEMBER ITA No. 871 to 874/Bang/2025 Assessment Year: 2014-15 & 2018-19 to 2020-21 Assessment Year: 2014-15 & 2018-19 to 2020-21 Assessment Year: 2014-15 & 2018-19 to 2020-21 Assessment Year: 2014-15 & 2018-19 to 2020-21 Assessment Year: 2014-15 & 2018-19 to 2020-21 Assessment Year: 2014-15 & 2018-19 to 2020-21 Assessment Year: 2014-15 & 2018-19 to 2020-21 Assessment Year: 2014-15 & 2018-19 to 2020-21 Assessee by : Shri H Guruswamy, ITP &

Shri Ravi Kiran, CA Revenue by : Shri Shivanad Kalakeri, CIT (DR)

Date of hearing : 12.11.2025 Date of Pronouncement : 28.01.2026

O R D E R

PER WASEEM AHMED, ACCOUNTANT MEMBER:

These four appeals for the Assessment Years 2014-15, 2018-19, 2019-20, and 2020-21 were heard together. The appeals, filed at the instance of the assessee, are directed against separate orders passed by the Learned Commissioner of Income Tax (Appeals)-15, Bengaluru (hereinafter referred to as the learned CIT(A)) under section 250 of the Income-tax Act, 1961 (hereinafter referred to as the Act).

2. The dispute in all four assessment years is interconnected and revolves around the income arising from the Joint Development Agreement (JDA) entered into by the assessee for the development of land property.

3. The issues/grounds of appeal raised by the assessee in the memoranda of appeal for all four assessment years are identical and are primarily technical in nature, revolving around the question of whether the income arising from the JDA is taxable in the hands of the HUF or in the individual capacity of the assessee. In addition, the assessee has raised an additional ground of appeal for Assessment Years 2014-15, 2018-19, and 2019-20, challenging the validity of the assessments framed under section 153A of the Act.

4. Without going into the technical or legal grounds raised by the assessee, we proceed to adjudicate the issue on the merits of the additions made in the relevant assessment years, namely Assessment Years 2014-15 and 2018-19 to 2020-21, on account of income arising from the JDA.

5. The facts in brief are that Sri Gurappa purchased land measuring 9 acres and 28 guntas, bearing Survey No. 92, in the year 1951. Sri Gurappa had four sons, namely:

(1) Sri Pilappa, (2) Sri Veerappa, (3) Sri Munireddy, and (4) Sri Hanumantha Reddy.

6. The eldest son, Sri Pilappa, executed a release deed dated 22 July 1955 in favour of his father, Sri Gurappa, and his three brothers, thereby relinquishing his rights in the impugned land property. After the death of Sri Gurappa, a registered partition deed dated 30 December 1960 was executed among his three sons, namely Sri Veerappa, Sri Munireddy, and Sri Hanumantha Reddy. As per the said partition deed, the land measuring 9 acres and 28 guntas was divided among them as under:

1. Sri Veerappa – 2 acres and 20 guntas 2. Sri Munireddy – 3 acres and 24 guntas

3. Sri Hanumantha Reddy – 3 acres and 24 guntas

7. Thereafter, the RTC and other revenue records were mutated in their respective names in accordance with their respective shares. Sri Munireddy, who was allotted 3 acres and 24 guntas under the partition deed of 1960, was the father of the present assessee-appellant. Upon the death of Sri Munireddy, the assessee and his siblings, being the legal heirs, entered into a partition suit. The suit was decreed by the court vide order dated 16 May 2011, and as per the said decree, the assessee was allotted 1 acre and 8 guntas in the impugned property. Consequently, the RTC and other revenue records were mutated in the name of the assessee, and a new Survey No. 92/2 was assigned to his share.

8. Subsequently, the assessee entered into a Joint Development Agreement dated 26 October 2013 with a developer, namely M/s Ecstasy Projects Pvt. Ltd., for the development of a residential project known as “Trifecta Joli.” In the JDA, the assessee made his wife and two minor daughter