Mandakini Tirthraj Pannase vs ITO, Ward-1(4), Nagpur

Parties Involved

Facts Summary

The assessee, Mandakini Tirthraj Pannase, filed an appeal against the order of the Additional Commissioner of Income Tax (Appeals) dated 23.01.2026, which arose from an assessment order dated 26.12.2016. The assessee's grievance was regarding the denial of a deduction under section 54F of the Income Tax Act, 1961, amounting to Rs. 28,43,857/-. The assessee had sold a piece of land for Rs. 60,00,000/- and invested the capital gain in purchasing two flats. The Assessing Officer allowed the deduction for only one flat, leading to the appeal. The appeal was dismissed by the Ld.CIT(A) due to non-compliance, but the assessee argued that the amendment in the Finance Act, 2014, was not retrospective and both flats should be considered.…

Legal Issues

• 1. Whether the amendment in the Finance Act, 2014, is retrospective or prospective?
• 2. Whether both flats purchased by the assessee should be considered for the deduction under section 54F?

Judgment Outcome

Decided in favour of Assessee.

Precedents Relied Upon

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