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Shri Dinesh Bhailalbhai Patel,, Anand vs The Dy.Cit, Intl. Taxn., Vadodara on 22 December, 2017 cites

C.S. Atwal vs Commissioner Of Income Tax Ludhiana And ... on 22 July, 2015

3. We have given our thoughtful consideration to rival contentions. Common case records comprising of development agreement dated 07.02.2012, sale deed dated 25.07.2013, Section 17(1A) of Registration Act, 1908, judicial precedents C. S. Atwal vs. CIT 378 ITR 244 (P&H), ACIT vs. Jawaharlal L. Agicha 75 taxmann.com 121 (Mum-trib), Lemes E. D'souza vs. ITO ITA No.5802/Mum/2013 dated 10.04.2017 and CIT vs. Subhash Vinayak Supnekar (2017) 77 taxmann.com 226 (Bombay) alongwith Board's CBDT circular nos. 359, 762, 794 dated 10.05.1983, 18.02.1998 & 09.08.2000 stand perused. Both the learned representatives reiterate their respective pleadings qua the issue in question as to whether it is the agreement dated 07.02.2012 or the last date of receiving the sale consideration in question which forms the relevant transfer for the purpose of computing six months time period for the purpose of reinvestment of the impugned capital gains.
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