IN THE INCOME TAX APPELLATE TRIBUNAL “PATNA” BENCH, PATNA BEFORE SHRI DUVVURU RL REDDY, VP AND SHRI RAJESH KUMAR, AM (Assessment Year:2016-17)

Dharmavir Kumar DC/ACIT, Circle-4, C/o Naseeb Prasad, Income Tax Department, Lok PaithaniNathpur,Narayan Chak, Nayak Jai Prakash Bhavan, New Vs.

Phulwari. Dak Bunglow Road, Bihar-800002 Patna-800001, Bihar (Appellant) (

Respondent)

PAN No. AVZPK4382P Assessee by : Shri Sudeep Sinha, AR Revenue by : Shri Md. A.H. Chowdhary, DR Date of hearing: 26.11.2025 Date of pronouncement: 09.12.2025

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 18.12.2024 for the AY 2016-17.

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

“1. For that the Ld. CIT(A) has erred both in law and on facts.

2. For that the Ld. CIT(A) has erred in confirming the addition of compensation of Rs.4,71,91,650 in the hands of the appellant u/s 50C of the Income Tax Act, 1961 under the head capital gains.

3. For that section 50C is not a charging section. It simply says what would be the full consideration for the purpose of section 48 of the