Section 54 Relief Upheld as Property Reinvestment Delay Beyond Assessee’s Control

Sanjeev Garg Vs ACIT (ITAT Delhi) Delay Beyond Assessee’s Control Not Fatal- Property Reinvestment Delay Excused — Section 54 Relief Upheld by Delhi ITAT Reopening Sustained but Relief Restored Assessee sold his 1/3rd share in an inherited property at Ghaziabad, during FY 2011-12. AO reopened the assessment u/s 147, disallowed indexed cost of improvement (₹8.87 lakh) &  exemption u/s 54 (₹38.62 lakh), &  computed total income at ₹80.68 lakh. The assessee challenged the reassessment as invalid & contrary to law. Key Grounds 1. Invalid reopening: No proper “reasons to b...