9911796707
TMI Blog2024 (11) TMI 698X X X X Extracts X X X X X X X X Extracts X X X X ..... tention taken by the learned counsel for the petitioner that the merits of the claim raised by the petitioner had been considered while deciding whether the application for condonation of delay for filing revised returns for the assessment year 2021-2022 should be granted or not. The fact that the merits of the claim raised by the petitioner was considered is clear from a reading of Exts.P7 and P8 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion 119(2)(b) of the Income Tax Act 1961, principally on the ground that the application for extension of time/condonation of delay in filing revised returns for the assessment tier 2021-2022 [in respect of the deceased parents of the petitioner] has been rejected after examining the merits of the claim raised by the petitioner. It is submitted that though Exts.P11 and P12 do not reflect the same, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on 09.06.2015. 4. Having heard the learned counsel for the petitioner and the learned Standing Counsel appearing for the respondents, I am of the view that there is some merit in the contention taken by the learned counsel for the petitioner that the merits of the claim raised by the petitioner had been considered while deciding whether the application for condonation of delay for filing revised r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... isions contained in Section 56(2) (viii) and Section 57(iv) of the Income Tax Act are unambiguous that the interest received on compensation/enhanced compensation is to be treated as Income under the head 'Other Sources' and not under the head Capital Gains. I am, therefore of the view that, the impugned orders are liable to be set aside and the applications filed by the petitioner for con ..... X X X X Extracts X X X X X X X X Extracts X X X X
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