THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 vs LATA GOEL

Judgment text excerpt

$~101 * IN THE HIGH COURT OF DELHI AT NEW DELHI % Date of Decision: 30.04.2025 + ITA 127/2025 & CM No.25518/2025 THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 .....Appellant Through: Mr. Ruchir Bhatia, Adv. Versus LATA GOEL .....Respondent Through: None. CORAM: HON'BLE MR. JUSTICE VIBHU BAKHRU HON'BLE MR. JUSTICE TEJAS KARIA VIBHU BAKHRU, J. (Oral) 1. The Revenue has filed the present appeal under Section 260A of the Income Tax Act, 1961 [Act] impugning an order dated 25.09.2024 [impugned order] passed by the Income Tax Appellate Tribunal [ITAT] in ITA No.3426/Del/2019 in respect of Assessment Year [AY] 2011-12. 2. The impugned order is a common order passed by the learned ITAT in ITA No.3426/Del/2019 and ITA No.5892/Del/2015. However, as stated above, the present appeal arises from ITA No.3426/Del/2019, which was preferred by the Assessee against an order dated 18.03.2019 passed by the Commissioner of Income Tax (Appeals)-24 [CIT(A)]. The said appeal, in turn, was filed against an assessment order dated 29.12.2017, passed by the Assessing Officer [AO] under Section 147 read with Section 143(3) of the ITA 127/2025 Page 1 of 10 Signature Not Verified Digitally Signed By:TARUN RANA Signing Date:13.05.2025 15:59:36 Act. 3. The subject matter of controversy in the appeals before the learned ITAT centres around the Assessee’s claim for deduction under Section 54F of the Act. 4. The Assessee filed her return of income for AY 2011-12 on 31.12.2011, declaring an income of ₹70,87,301/-. The Assessee also claimed a deduction of ₹90 crores under Section 54F of the Act asserting that the consideration received from the sale of shares of FIITJEE Ltd. — an unlisted company, the gains from which would otherwise be chargeable to tax as capital gains — was invested in acquiring a resid