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56. [2026] 138 ITR(T) 617 (Chennai - Trib.)
Melongos India (P.) Ltd. v. Income Tax Officer
A.Y.: 2013-14, 2014-15 & 2015-16 DATE: 25.03.2026
Sec. 45 read with sections 50C and 2(47), and Sec. 54D read with sections 54F and 54G – Capital gains – Assessee transferred immovable property through eight registered sale deeds executed across FYs 2012-13 to 2014-15 but offered entire LTCG in AY 2014-15 – Each registered sale deed constituted independent transfer and capital gains chargeable in respective years of transfer – Fresh claims for deductions under sections 54D, 54F and 54G though not made in original/revised return to be examined on merits by AO as restriction under Goetze (India) Ltd. applies only to AO and not to appellate authorities.
FACTS
The assessee-company owned immovable property situated in Chennai, which was acquired during FY 2004-05 for a consideration of Rs. 3,00,00,000 and transferred through eight registered sale deeds executed across FYs 2012-13, 2013-14 and 2014-15 for an aggregate sale consideration of `7,40,95,500. The assessee offered the entire long-term capital gains in AY 2014-15.
During scrutiny for AY 20
