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Jaipal Vs. ITO

Case No: ITA No. 3279/Del/2018
Court: INCOME TAX APPELLATE TRIBUNAL DELHI (DELHI BENCH ‘F’ NEW DELHI)
Date: 1/14/2026

Parties Involved

appellantJaipal
respondentITO

Facts Summary

The case involves an assessment order passed under section 147 of the Income Tax Act, 1961, on 22/03/2016, where the Assessing Officer made certain additions and computed the income of the assessee at Rs. 80,56,680/-. The assessee had filed a return of income showing Rs. 1,15,583/-. Aggrieved by this order, the assessee appealed to the Commissioner of Income Tax (Appeals)-1, Gurgaon, who partly allowed the appeal. The assessee then filed the present appeal against the order of the CIT(A). The case was reopened under section 148 due to cash deposits exceeding Rs. 10,00,000/- in the assessee's bank account. During reassessment, the Assessing Officer noted a credit entry of Rs. 98,87,500/- and computed long-term capital gains from the sale of land. The assessee contested various aspects of the assessment, including the reopening of assessment, the computation of long-term capital gains, and the denial of certain deductions.

Decision in favour of

Revenue

Legal Issues

  • 1. Validity of reopening the assessment under section 148
  • 2. Computation of long-term capital gains
  • 3. Denial of deduction under section 54F
  • 4. Charging of interest under section 234A
  • 5. Validity of reassessment proceedings initiated on suspicion

Judgment Outcome

Decided in favour of Revenue.

Precedents Relied Upon

6 precedents cited in this judgement.

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Jaipal Vs. ITO | ITA No. 3279/Del/2018 | 2026 | Opakhya