Nakul Aggarwal vs Assistant Commissioner of Income Tax, Circle-24(1), Mumbai

Parties Involved

Facts Summary

The assessee, Nakul Aggarwal, filed his income return for the assessment year 2017-18, claiming a deduction under Chapter VIA of the Income-tax Act, 1961. The case was selected for scrutiny to verify the deduction/exemption from capital gains, investment in immovable property, and foreign assets. The assessee claimed deduction under section 54F of the Act for purchasing a residential property. The Assessing Officer disallowed the deduction, leading to an appeal by the assessee. The Commissioner of Income-tax (Appeals) allowed the deduction on a pro-rata basis. Both the assessee and the revenue filed appeals before the Tribunal.…

Legal Issues

• 1. Whether the assessee is eligible for exemption under section 54F of the Act for purchasing two residential houses which were later merged into one single unit?
• 2. Whether the conversion of a company into an LLP is a taxable transfer under the Act?

Judgment Outcome

Decided in favour of Partly Assessee / Partly Revenue.

Precedents Relied Upon

Similar Judgements

• Dhruval Kirit Sukhadia vs. The Deputy Commissioner of Income Tax

  Ahmedabad bench

• Namitha Deenadayalu Naidu vs. ITO

  C'' Bench: Bangalore benchAY 2016-17Partly Allowed

• Shri Kirankumar Rasiklal Sanghvi Vs. PCIT

  Ahmedabad bench

• Sannidhi Sriramachandra Murthy (HUF) v. The Assistant Commissioner of Income Tax, Circle-1

  Visakhapatnam bench

• ITA No. 6577/Del/2025 (A.Y 2017) ACIT Vs. Pushpa Aggarwal

  Delhi bench

• ITA No. 8234/Mum/2025 (A.Y. 2012-13)

  Mumbai bench