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INCOME TAX APPELLATE TRIBUNAL (DEHRADUN BENCH)
Yogesh Kumar U.S, Judicial Member, Manish Agarwal, Accountant Member
Anil Singh – Appellant
Versus
DCIT – Respondent
| Table of Content |
|---|
| 1. assessment and reclassification of land sale proceeds as long term capital gains. (Para 4 , 5 , 6 , 7 , 10 , 11 , 13) |
| 2. validating reassessment proceedings initiated under section 147 based on tangible information despite previous disclosure. (Para 8 , 9 , 12 , 16) |
ORDER
PER YOGESH KUMAR U.S, JM :
The captioned appeals are filed by the assessee against the separate orders, both dated 14.10.2024 by Ld. Commissioner of Income Tax (A)-3, Noida [“Ld. CIT(A)”] passed u/s 250 of the Income Tax Act, 1961 [“the Act”] arising from the different assessment orders, both dated 16.03.2022 passed u/s 147 of the Act pertaining to Assessment Year 2015-16 and 2016-17 respectively.
2. The issues involved in both captioned appeals are common, therefore, they were heard together and accordingly, adjudicated by a common order.
3. First we take the appeal of the assessee in ITA No.196/DDN/2024 for Assessment Year 2015-16.
4. Brei facts are that the assessee owned half share in a piece of land i.e. 50% of 5.1740 Hectares at Rani Pokhari Grant at Dehradun district. During the year under appeal, the assessee has converted the said land into “Aawasiya” and sold it after dividi
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