LAWS(ORI)-2025-7-2

ANTARJYAMI MOHAPATRA Vs. CENTRAL BOARD OF DIRECT TAXES

Decided On July 24, 2025
Antarjyami Mohapatra Appellant
V/S
CENTRAL BOARD OF DIRECT TAXES Respondents

JUDGEMENT

(1.) Assailing the assessment order dtd. 21/3/2023 passed under Sec. 147 and Sec. 144 read with Sec. 144B of the Income Tax Act, 1961, by the National Faceless Assessment Unit, New Delhi for the Assessment year 2018-19 under Annexure-1 in contravention of Sec. 48 ibid., as same income could not be made to suffer taxation again for the Assessment year 2019-20 basing on information available in Form 26AS in the webportal of the Income Tax Department, the petitioner has come up before this Court by way of filing this writ petition under Articles 226 and 227 of the Constitution of India, craving for grant of following relief(s): "Under the aforesaid facts and circumstances, it is prayed that this Hon'ble Court may be graciously pleased to-

(2.) The petitioner in need of finances for discharging legal necessities, sold his agricultural land on 12/2/2018 by dint of registered sale deeds to two different persons for total consideration of Rs.61,87,500.00, which he has disclosed as capital gains for the Assessment Year 2019- 20 and also discharged his liability on self-assessment.

(3.) On the concession of counsel for the both sides, this matter is taken up for final hearing at the stage of admission. Accordingly, heard Sri Tushar Kanti Satapathy, learned Advocate for the petitioner and Sri Subash Chandra Mohanty, learned Senior Standing Counsel along with Sri Avinash Kedia, learned Junior Standing Counsel for the Central Board of Direct Taxes (CBDT)-Opposite Parties. Rival contentions and submissions: