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IN THE INCOME TAX APPELLATE TRIBUNAL

“B” BENCH, AHMEDABAD

BEFORE DR. B.R.R. KUMAR, VICE-PRESIDENT

SHRI SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER

ITA No.1061/Ahd/2025

(Assessment Year: 2015-16)

The ITO

Ravindrabhai Shankarbhai

Vs.

Ward-1(2)(5).

Patel

Now ITO, Ward-1(2)(2)

86,Kanha Residency

Vadodara – 390 007

Kalali Road, Kalali

Ahmedabad – 390 012

[PAN : AIGPP 8415 M

(Appellant) .. (Respondent

Assessee represented by : Ms. Urvashi Shodhan, AR

Revenue represented by : Shri Abhijit, Sr.DR

Date of Hearing 27/11/2025

Date of Pronouncement 29/01/2026

O R D E R

PER SIDDHARTHA NAUTIYAL, JUDICIAL MEMBER:

The present appeal has been filed by the assessee against the order of the

Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC),

Delhi [hereinafter referred to as the “the CIT(A)”] dated 25/04/2025 passed for

Assessment Year (AY) 2015-16.

2. The Assessee has raised the following grounds of appeal:

“1. The learned CIT (A) has erred in law and on the facts of the appellant's case in

confirming addition of ₹1,66,98,526/- under Income from Capital Gain instead of

"NIL".

2. The learned CIT (A) has erred in law and on the facts of the appellant's case in

confirming disallowance of deduction U/s 54B of the Act of ₹1,50,26,830/- on the

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ITA No.1061/Ahd/2025

Ravindrabhai Shankarbhai Patel vs. ITO

A.Y: 2015-16

erroneous plea that the appellant has not complied with provisions of Section 54B

of the Act.

3. The learned CIT (A) has erred in law and on the facts of the appellant's case in

confirming disallowance of deduction U/s 54F of the Act of ₹16,71,696/- on the

erroneous plea that the appellant has not complied with provisions of Section 54F

of the Act.

4. Both the lower authorities have erred in law and on the facts of the appellant's

case in not appreciating the fact that the appellant has duly complied all the

conditions for claiming deduction U/s 54B & 54F of the Act.

5. The appellant craves leave to add, amend, alter, edit, delete, modify or change

all or any of the grounds of appeal at the time of or before the hearing of the

appeal.”

3. The brief facts of the case are that the assessee is an individual engaged in the

business of retail trading of furniture and, during the year under consideration, had

income from capital gains and income from other sources. For Assessment Year

2015–16, the assessee filed his return of income on 18.03.2016 under section 139(4)

of the Income-tax Act declaring a total income of Rs.78,36,110/-. The case was

selected for scrutiny and assessment was completed by the Assessing Officer under

section 143(3) of the Act on 29.12.2017 determining the total income at

Rs.1,75,34,640/-.

3.1. During the year, the assessee along with his wife, who was a co-owner with

50 per cent share, sold an agricultural land situated at Village Kalali, Vadodara, for

a total consideration of Rs.4,29,00,000/-. The assessee’s share in the sale

consideration was Rs.2,14,50,000/-. The assessee claimed that the land was

transferred during the previous year relevant to the assessment year under

consideration and declared long-term capital gains arising from the said transfer.

Against the capital gains, the assessee claimed deduction under section 54B of the

Act on the ground that he had invested the capital gains in purchase of other

agricultural lands, and deduction under section 54F of the Act on the ground that he

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ITA No.1061/Ahd/2025

Ravindrabhai Shankarbhai Patel vs. ITO

A.Y: 2015-16

had invested in purchase of a plot and construction of a residential house. The

assessee also claimed that part of the capital gains was deposited in the Capital Gain

Account Scheme. After claiming indexed cost of acquisition, brokerage and other

expenses, and deductions under sections 54B and 54F, the assessee returned the

taxable long-term capital gain at Nil.

4. During the assessment proceedings, the Assessing Officer examined the claim

of deductions under sections 54B and 54F. The Assessing Officer noted that

substantial amounts claimed as investment in agricultural land, re