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Case Law Details

Case Name : Prabha Anil Gandhi Vs ADIT (ITAT Mumbai)
Appeal Number : ITA NO. 1647/MUM/2023
Date of Judgement/Order : 25/10/2023
Related Assessment Year : A.Y: 2019-20
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Prabha Anil Gandhi Vs ADIT (ITAT Mumbai)

Prabha Anil Gandhi vs. ADIT (ITAT Mumbai): ITAT rules on CPC’s jurisdiction, Section 50C adjustments, and processing under section 143(1).

The recent case of Prabha Anil Gandhi Vs. ADIT (ITAT Mumbai) brings to light an essential aspect regarding the jurisdiction of the Centralized Processing Centre (CPC) in making additions under section 50C of the Income Tax Act, 1961. The case pertains to the Assessment Year 2019-20, where the Assessing Officer (CPC) proposed an addition under section 50C during the processing of the return u/s. 143(1) of the Act.

Background of the Case:

Prabha Anil Gandhi, the assessee, filed her return of income for the A.Y. 2019-20, declaring Long Term Capital Gains of ₹3,22,370/-. The Assessing Officer, during the processing of the return u/s. 143(1), observed that the Long Term Capital Gains were computed at ₹53,22,370, and the assessee claimed exemption u/s. 54EC after depositing ₹50,00,000 in eligible bonds. The Assessing Officer, invoking section 50C, made an adjustment by taking the stamp duty valuation of ₹13,29,23,000 against the declared full value of consideration of ₹10 crores.

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