This compilation indexes 12 rulings — 11 from various benches of the Income Tax Appellate Tribunal and 1 from the Kerala High Court — in which Section 10(37) of the Income Tax Act, 1961 was directly in issue. The rulings span January 2023 to June 2026 and arise from appeals across Pune, Chennai, Rajkot, Nagpur, Patna, Lucknow, Amritsar, and Ernakulam. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a structured, citation-traceable starting point for research on the exemption available to individuals on compensation received for compulsory acquisition of urban agricultural land.

Research index only. This page is a structured case-law reference tool, not legal or tax advice. Readers must independently verify rulings against full judgment texts, check for subsequent stays, reversals, or appeals, and consult qualified professionals before acting on any information contained herein.

The statutory framework in one paragraph

Section 10(37) of the Income Tax Act, 1961 provides an exemption from income tax in respect of any income chargeable under the head "Capital Gains" arising to an individual or a Hindu Undivided Family (HUF) from the transfer of agricultural land, where: (a) such land is situate in an area referred to in item (a) or item (b) of sub-clause (iii) of clause (14) of Section 2 (i.e., urban agricultural land falling within the definition of "capital asset"); (b) such transfer is by way of compulsory acquisition under any law; and (c) the compensation or enhanced compensation or consideration for such transfer is received on or after the 1st day of April 2004. The exemption is personal in nature and is available only to individuals and HUFs, not to companies or other entities.

The 12 rulings

1. Maruti Dagadu Ranjane, Vahagaon vs Assessing Officer Ward 4 Satara, Aaykar

Bench: Income Tax Appellate Tribunal - Pune
Date: 29 June 2026
Sections engaged: 10(37)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA 814/PUN/2026) was filed by the assessee against the order of the Commissioner of Income Tax (Appeals), Pune, which sustained an addition made by the Assessing Officer for Assessment Year 2015-16. Per the source preview, the Assessing Officer had received information that the assessee had sold immovable property but had not filed a return of income for AY 2015-16, leading to proceedings under the Act. The appeal was directed against the CIT(A)'s order challenging the addition so sustained.

2. Sundaramahalingam Narayanan, Chennai vs Income Tax Officer, Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 15 June 2026
Sections engaged: 10(37), 2(14)(iii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 438/Chny/2025) was directed against the order of the Commissioner of Income Tax (Appeals) - 20, Chennai dated 16.12.2024, which arose out of an assessment order dated 27.03.2015 passed by the Income Tax Officer, Non-Corporate Ward 14(1), Chennai for Assessment Year 2012-13. Both Section 10(37) and Section 2(14)(iii) were cited, indicating the dispute involved the characterisation of the transferred land as a capital asset and the applicability of the exemption on compensation received.

3. Jesabhai Rajabhai Khtana, Khajuri vs Income-Tax Officer, Ward-1(2)(3)

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 30 March 2026
Sections engaged: 10(37), 56(2)(viii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 279/RJT/2025) for Assessment Year 2016-17 was heard alongside connected appeals of Babubhai Punabhai Sakariya (ITA No. 328/RJT/2025) and Savitaben Dayabhai Sakariya (ITA No. 327/RJT/2025), all involving the Income Tax Officer, Ward-1(2)(3), Rajkot for Assessment Year 2016-17. The matter was originally heard on 27.11.2025 and pronounced on 30.03.2026. The engagement of Section 56(2)(viii) alongside Section 10(37) suggests the dispute involved the treatment of compensation received in the context of land acquisition proceedings.

4. Yash Travels And Tours Private vs The Income Tax Officer Ward - 2(2)

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 26 March 2026
Sections engaged: 10(37), 96
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 481/NAG/2025) was directed against the order of the National Faceless Appeal Centre, Delhi/CIT(A) dated 18/06/2025 for Assessment Year 2023-24. The assessee, Yash Travels and Tours Pvt. Ltd. (PAN: AAACY3931D), filed the appeal and rival submissions of both parties were heard. The citation of Section 96 alongside Section 10(37) is notable; Section 96 of the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 provides that compensation awarded under that Act is exempt from income tax, and its interplay with Section 10(37) of the Income Tax Act is a recurring issue in land acquisition matters.

5. Dharmavir Kumar, Patna vs Dc/Ac Circle 4, Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 9 December 2025
Sections engaged: 10(37), 96
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 70/PAT/2025) was filed by the assessee against the order of the National Faceless Appeal Centre, Delhi dated 18.12.2024 for Assessment Year 2016-17. Per the source preview, the assessee filed a return of income on 04.03.2017 declaring a total income of Rs. 12,40,390/-, and the case was selected for scrutiny with assessment framed under the Act. The citation of Section 96 alongside Section 10(37) indicates the dispute likely concerned the tax treatment of compensation received in connection with land acquisition.

6. Usha Yadav, Lucknow vs Income Tax Officer Range 6(2), Lucknow

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 9 December 2025
Sections engaged: 10(37), 2(14)(iii)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals (ITA Nos. 249 & 251/LKW/2024) for Assessment Year 2013-14 were heard together and disposed of by consolidated order. Per the source preview, the Assessing Officer noted that the assessee had failed to furnish a return of income within the time allowed, and thereafter the AO was in possession of information regarding the assessee having received a sum — the nature of which is not further detailed in the available preview. The engagement of Section 2(14)(iii) alongside Section 10(37) indicates the dispute involved whether the land transferred qualified as a capital asset and whether the exemption was applicable.

7. Kantaben Vajubhai Paghadal, Rajkot vs ITO Wd 1(2)(1), Rajkot, Rajkot

Bench: Income Tax Appellate Tribunal - Rajkot
Date: 28 November 2025
Sections engaged: 10(37)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 552/RJT/2025) for Assessment Year 2016-17 was directed against the order passed under section 250 by the National Faceless Appeal Centre (NFAC), Delhi/Commissioner of Income Tax (Appeals) dated 20/03/2025, which arose out of an order passed by the Assessing Officer dated 05/12/2018. Per the source preview, the appeal was barred by limitation by 84 days and the assessee filed a petition for condonation of delay; the bench noted that the reasons given in the affidavit were convincing and proceeded to consider the condonation.

8. George Stanley vs The Deputy Commissioner Of Income Tax

Bench: Kerala High Court
Date: 25 August 2025
Sections engaged: 10(37)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 45 of 2024, citation 2025:KER:64834) was filed by the assessee before the Kerala High Court at Ernakulam, questioning the findings of the Income Tax Appellate Tribunal, Cochin Bench in ITA No. 587 of 2022 (order dated 31.10.2023). The matter involved the Deputy Commissioner of Income Tax, International Taxation Circle, Thiruvananthapuram, and the assessment order under challenge was dated 28.12.2016. The appeal was finally heard and decided on 25.08.2025. This is the only High Court ruling in this compilation and the only one involving the International Taxation Circle.

9. Dina Nath Yadav, Patna vs ITO Ward - 4(2), Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 19 May 2025
Sections engaged: 10(37), 96
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 303/PAT/2024) for Assessment Year 2016-17 arose from an order passed by the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 25.08.2023. Per the source preview, the assessee received an amount of Rs. 1,20,91,266/- as compensation against acquisition of land under the NH Act, 1956, and TDS was made under the Act. The Assessing Officer's treatment of this compensation, and the applicability of Section 10(37) and Section 96, formed the subject matter of the dispute.

10. Baiju Roy, Patna vs ITO, Ward-4(2), Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 2 June 2023
Sections engaged: 10(37)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 13/PAT/2022) for Assessment Year 2016-2017 was heard at the Kolkata-Patna e-Court. Per the source preview, the CIT(Appeals) had erred in not condoning the delay and deciding the appeal on merit — this ground was raised by the assessee. The preview also records the computation of long-term capital gains on sale consideration of Rs. 1,25,05,763/- with cost of acquisition taken as nil, resulting in a total income figure. The engagement of Section 10(37) indicates the assessee sought exemption from tax on the capital gains so computed.

11. Income Tax Officer Ward-2 (1), Jammu vs Shri Mohd Aslam Baggar, Jammu

Bench: Income Tax Appellate Tribunal - Amritsar
Date: 28 February 2023
Sections engaged: 10(37), 45(5)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (I.T.A. No. 104/Asr/2020) for Assessment Year 2015-16 was filed by the Revenue against the order of the Commissioner of Income Tax (Appeals), Jammu dated 22.11.2019. Per the source preview, the Revenue's ground was whether, if the date of transfer of the impugned land measuring 74 Kanal 08 Marla was taken as 19.05.2014 (the date of the final award of compensation), the CIT(A) was right in holding the entire compensation received as exempt under Section 10(37). The simultaneous citation of Section 45(5) indicates the dispute also involved the computation of capital gains on compulsory acquisition.

12. ITO, Ward-4(1), Patna vs Jagdish Ray, Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 4 January 2023
Sections engaged: 10(37)
Outcome: Outcome not specified in source
Procedural / substantive ground: The captioned appeal (ITA No. 102/Pat/20) and a corresponding cross objection (CO No. 01/Pat/2021) for Assessment Year 2014-15 were heard together at ITAT Kolkata through virtual medium. Both the Revenue's appeal and the assessee's cross objection were directed against the same underlying order. The matter involved Jagdish Ray of Nawada, Patna, and the Revenue's challenge concerned the application of Section 10(37) to the facts of Assessment Year 2014-15.

Patterns across these 12 rulings

Persistent AY 2015-16 and 2016-17 vintage. A majority of the rulings — cases 1, 3, 5, 6, 7, 9, 10, and 11 — concern Assessment Years 2015-16 or 2016-17, suggesting that disputes relating to compulsory land acquisition compensation from that period continue to generate appellate litigation into 2025 and 2026.
Frequent co-citation of Section 96. Four rulings (cases 4, 5, 8 in section-list terms, and 9) cite Section 96 alongside Section 10(37). This indicates a recurring issue before tribunals as to whether the exemption under the land acquisition statute and the income-tax exemption under Section 10(37) operate cumulatively or independently, particularly in acquisitions under the Right to Fair Compensation and Transparency in Land Acquisition, Rehabilitation and Resettlement Act, 2013 and the National Highways Act, 1956.
Section 2(14)(iii) as a threshold dispute. Three rulings (cases 2, 6, and implicitly others involving urban agricultural land) co-cite Section 2(14)(iii), the definitional provision for "capital asset" in relation to agricultural land. This reflects that the gateway question — whether the land transferred is a capital asset at all — is frequently contested before the exemption question under Section 10(37) is even reached.
Revenue-initiated appeals are present. While most appeals are filed by assessees, case 11 (ITO Ward-2(1), Jammu vs Mohd Aslam Baggar) and case 12 (ITO Ward-4(1), Patna vs Jagdish Ray) are Revenue appeals challenging CIT(A) orders that had allowed the Section 10(37) exemption. This indicates the exemption claim is contested in both directions at the appellate stage.
Delay condonation as a recurring procedural issue. At least two rulings (cases 7 and 10) reflect preliminary disputes over condonation of delay in filing appeals before the Tribunal. In case 7, the bench noted that the reasons in the affidavit were convincing; in case 10, the ground raised was that the CIT(A) erred in not condoning the delay. Procedural gateway issues thus form a distinct sub-theme within this Section 10(37) litigation corpus.

How to use this compilation

This compilation is a structured starting point for legal and tax research. Each entry provides the case identity, bench, date, sections engaged, and a brief procedural note drawn strictly from the available source preview. Before relying on any ruling in a matter, researchers should obtain and read the full text of the judgment from the official court portal (indiankanoon.org, the Income Tax Appellate Tribunal's official website, or the respective High Court's website) to verify the complete factual matrix, the precise ratio, and the dispositive order. The outcome field for all 12 cases in this compilation is recorded as "Outcome not specified in source," which means the source preview available in the TaxNoticeAI corpus did not contain a complete operative paragraph; the full judgment must be consulted to determine the final direction of each ruling.

Researchers should further check whether any of these orders have been the subject of subsequent proceedings — including further appeals to the High Court or Supreme Court, applications for stay, or rectification proceedings — that may have altered or reversed the Tribunal's or High Court's findings. Legal databases such as SCC Online, Manupatra, and Tax Management India (TMI) can be used to trace the subsequent history of each ruling.

Finally, researchers should be aware that CBDT has from time to time issued circulars and instructions addressing the interpretation of Section 10(37) and related provisions, including in the context of enhanced compensation and solatium. Any research exercise on Section 10(37) should include a parallel check of current CBDT guidance to ensure that administrative positions are accounted for alongside judicial holdings.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Section 10(37) Income Tax Exemption: 12 ITAT and HC Rulings (2023–2026)