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In the matter of grant of capital gains exemption u/54B with respect to back to back sale with purchase of agricultural land under general power of attorney/agreement to sale document the delhi tribunal in (2022] 100 ITR (Trib) 252 (ITAT[Del]) held that what transpired in such purchase is acquisition of rights of property and interest in a capital asset within the meaning of section 2(14)/2(47) of income tax act and that therefore the decision of the Supreme Court in the case of Suraj Lamp and Industries P. Ltd. v. State of Haryana [2012] 340 ITR 1 (SC) (SLP (C) No. 13917 of 2009, dated October 11, 2011) to hold otherwise as invalid under the law any sale through unregistered sale does not pose any hindrance in the matter of grant of exemption. 

The bench allowed such exemption on production of  copy of Income-tax return of selling party declaring their capital gains on such very transaction. 

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