This compilation indexes 12 rulings — spanning the Income Tax Appellate Tribunal and multiple High Courts — in which the citation string "Section 54(1)" appears in the sections engaged. Researchers should note at the outset that "Section 54(1)" is not a uniform provision: depending on the statute under which a given case arises, it may refer to Section 54(1) of the Income Tax Act 1961 (capital-gains exemption on reinvestment in residential property), Section 54(1) of the Central Goods and Services Tax Act 2017 (two-year limitation for refund applications), or Section 54(1)(14) of the U.P. Value Added Tax Act 2008 (penalty for goods interception). Each case section below identifies the governing statute from its source preview where ascertainable. This index is intended for in-house tax teams, Big-4 associates, and law firm researchers who need a consolidated starting point for locating primary source documents.

Research index only. Nothing in this article constitutes legal advice, tax advice, or any form of professional opinion. Verify every ruling against the full authenticated judgment before relying on it in any matter.

The statutory framework in one paragraph

Section 54(1) of the Income Tax Act, 1961, provides an exemption from capital gains tax arising on the transfer of a long-term capital asset being a residential house, to the extent the net consideration (or capital gains, subject to conditions) is reinvested in the purchase or construction of another residential house property within the prescribed time limits. The Central Goods and Services Tax Act, 2017 contains its own Section 54(1), which prescribes that any person claiming a refund of tax, interest, penalty, fees or any other amount paid under that Act may make an application to the proper officer before the expiry of two years from the relevant date. The U.P. Value Added Tax Act, 2008 contains Section 54(1)(14), which operates in the context of penalties for irregularities detected during interception of goods in transit. Because the section number "54(1)" spans these materially different statutory regimes, each ruling below must be read strictly within its own statutory context.

The 12 rulings

1. Dr. Adil Agarwal,Chennai vs DCIT, Corporate Circle-1(1), Chennai

Bench: Income Tax Appellate Tribunal - Chennai
Date: 14 July 2026
Sections engaged: 54(1), 54F, 54F(1), 54F(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed before the Income Tax Appellate Tribunal, Chennai (ITA No. 3732/Chny/2025) for Assessment Year 2023-24, bearing PAN AEHPA 3177 M. Per the source preview, the case involves a summary computation of long-term capital gains from the sale of shares under section 112A amounting to ₹29,52,67,577, reduced by a carried-forward long-term capital loss of ₹3,39,00,000, yielding net capital gains of ₹26,13,67,577, with cost of new property computed at ₹27,24,00,000 and sale consideration at ₹29,70,37,500, resulting in an eligible exemption calculation of ₹23,96,88,686 under the proportionate formula.

2. Pranav Overseas Llp vs Union Of India

Bench: Gujarat High Court
Date: 2 July 2026
Sections engaged: 2(62), 54(1), 54(3)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/Special Civil Application No. 12861 of 2020) was filed before the Gujarat High Court at Ahmedabad. Per the source preview, the matter involves subsequent developments in law relating to Rule 89(5) of the Central Goods & Service Tax Rules, 2017, following the Supreme Court's decision in Union of India & Ors. vs. VKC Footsteps India Pvt. Ltd., (2022) 2 SCC 603, which set aside an earlier Gujarat High Court order; the petition appears to engage Section 54(1) in the context of the CGST Act, and the GST Counsel had issued a notification pursuant to Supreme Court directions.

3. Hirenkumar Valjibhai Sankhalava vs Office Of Deputy Commissioner Of State

Bench: Gujarat High Court
Date: 25 June 2026
Sections engaged: 107, 54(1), 67(2), 73
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/Special Civil Application No. 8399 of 2026) was filed before the Gujarat High Court at Ahmedabad and was approved for reporting. Per the source preview, the court was initially not inclined to entertain the petition on the ground that an alternative efficacious remedy of filing an appeal under Section 107 of the Gujarat Goods and Services Tax Act, 2017 was available; on the petitioner's request, the matter was relisted and the petitioner elected to proceed on merits rather than avail the statutory remedy.

4. Rajendra Narayan Mohanty vs Joint Commissioner Of State Tax

Bench: Orissa High Court
Date: 12 February 2026
Sections engaged: 54(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ application (W.P.(C) No. 2271 of 2026) was filed before the Orissa High Court at Cuttack under Articles 226 and 227 of the Constitution of India. Per the source preview, the petitioner bearing GSTIN 21ABCPM1806F1ZD sought, among other reliefs, a writ in the nature of certiorari quashing the impugned order, and a writ of mandamus directing the Joint Commissioner to refund an alleged excess payment of tax of ₹6,01,644 each under the CGST and SGST Acts, purportedly paid through DRC-03 dated 18.09.2022.

5. Bharat Oil Traders vs Assistant Commissioner & Anr

Bench: Jammu & Kashmir High Court
Date: 30 December 2025
Sections engaged: 54(1), 54(3)(ii)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (WP(C) No. 192/2023) was reserved on 09.07.2025 and the full judgment pronounced on 30.12.2025 before the High Court of Jammu & Kashmir and Ladakh at Jammu. Per the source preview, the petitioner is a partnership firm engaged in refilling and sale of edible oil and ghee, registered under the State and Central Goods and Services Tax Acts, 2017; its business involves an inverted tax structure where input tax rates exceed output supply rates, and the petition concerns entitlement to claim a refund of accumulated input tax credit under the CGST/SGST Act with reference to the two-year "relevant date" limitation applicable to refund applications.

6. M/S Aps Powertech India Pvt. Ltd vs Commissioner Of Commercial Tax U.P

Bench: Allahabad High Court
Date: 1 August 2024
Sections engaged: 54(1), 50
Outcome: Outcome not specified in source
Procedural / substantive ground: The revision (Sales/Trade Tax Revision No. 41 of 2014, Neutral Citation No. 2024:AHC-LKO:52762) was filed before the Allahabad High Court, Lucknow Bench, assailing an order dated 13.02.2014 passed by the Trade Tax Tribunal in Second Appeal No. 195 of 2012 relating to assessment year 2010-11. Per the source preview, the matter arises from the interception of Vehicle No. UP 84C9459 by the Mobile Squad Authority on 04.01.2011, where Form 38 accompanying goods being imported from outside the State was found to have certain blank columns, giving rise to a show cause notice for levying penalty under Section 54(1)(14) of the U.P. Value Added Tax Act, 2008.

7. Qutone Ceramic Private Limited vs Commissioner (Appeals), GST And

Bench: Gujarat High Court
Date: 14 June 2024
Sections engaged: 54(1), 54(3)(i)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (R/Special Civil Application No. 4014 of 2024, Neutral Citation No. C/SCA/4014/2024) was filed before the Gujarat High Court at Ahmedabad. Per the source preview, the matter was heard and ruled upon as an oral judgment; the available preview is procedural in nature, confirming appearances of counsel for both sides and recording that rule was made returnable forthwith, with substantive grounds not fully visible in the source extract.

8. Hindustan Everest Tools Ltd.Lko vs The Commissioner Commercial Taxes

Bench: Allahabad High Court
Date: 23 January 2024
Sections engaged: 54(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The revision (Sales/Trade Tax Revision No. 29 of 2013, Neutral Citation No. 2024:AHC-LKO:6490) was filed before the Allahabad High Court, Lucknow Bench, assailing the judgment and order dated 13.12.2012 of the Commercial Tax Tribunal, Bench-I, Lucknow in Second Appeal No. 263 of 2013, which had dismissed the revisionist's appeal for Assessment Year 2009-10 and upheld a penalty under the U.P. VAT Act. Per the source preview, the goods were accompanied by all proper documents, invoices, and G.R. Form-38, and the revisionist's position was that it lacked knowledge of the newly introduced system for downloading Form-38 from the Commercial Tax Department's official website.

9. M/S Sethi Sons ( India ) vs Assistant Commissioner And Ors

Bench: Delhi High Court
Date: 22 December 2023
Sections engaged: 54(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.(C) 4179/2022) was filed before the Delhi High Court, aggrieved by denial of refund of unutilised input tax credit accumulated in respect of GST paid on inputs for zero-rated supplies (goods exported without payment of IGST) during the period from July 2017 to March 2018. Per the source preview, the Proper Officer had rejected the petitioner's refund application by an Order-in-Original dated 11.03.2020 on the ground that it was filed beyond the period of two years as specified under Section 54(1) of the CGST Act, 2017, and the subsequent appeal before the Appellate Authority was also rejected by an Order-in-Appeal dated 06.08.2021.

10. Star Publishers Distributors vs Assistant Commissioner Of Cgst, Range 1

Bench: Delhi High Court
Date: 11 October 2023
Sections engaged: 54(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.(C) 12900/2023) was filed before the Delhi High Court impugning an order dated 30.06.2023 rejecting the petitioner's appeal against a refund rejection order dated 31.05.2021. Per the source preview, the petitioner had sought refund of input tax credit amounting to ₹13,71,484 (covering the periods 01.06.2018 to 31.03.2019 amounting to ₹8,75,068 and 01.04.2019 to 31.03.2020 amounting to ₹4,96,416); while the latter period's refund was allowed, the earlier period's refund was rejected on the ground that the application was filed beyond the period stipulated under Section 54(1) of the CGST Act, 2017.

11. Delhi Metro Rail Corporation Ltd vs The Additional Commissioner, Central

Bench: Delhi High Court
Date: 18 September 2023
Sections engaged: 54(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The writ petition (W.P.(C) 6793/2023) was filed before the Delhi High Court impugning Order-in-Appeal No. 241/2022-2023 dated 24.02.2023, which had rejected DMRC's appeal against an order dated 04.07.2022. Per the source preview, DMRC was aggrieved by the denial of a refund of ₹2,90,520 deposited under a mistake — a refund that was stated to be undisputed on merits — but which was rejected solely on the ground that the application was filed beyond the two-year period stipulated under Section 54(1) of the CGST Act, 2017; the factual background involves DMRC's engagement by Surat Municipal Corporation for preparation of a metro rail project report.

12. M/S S.B. Enterprises vs Commissioner Of Commercial Tax Lko

Bench: Allahabad High Court
Date: 29 April 2022
Sections engaged: 50(2)(a), 54(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: The revision (Sales/Trade Tax Revision No. 308 of 2015) was filed before the Allahabad High Court against the judgment and order dated 13.02.2015 of the Commercial Tax Tribunal, Division-I, Allahabad in Second Appeal No. 196 of 2014, arising out of penalty proceedings for assessment year 2011-12. Per the source preview, goods (545 batteries) were being transported from Pune, Maharashtra in vehicle bearing registration no. UP 78 CN 9050 with all requisite documents accompanying the consignment, but only column no. 3 of Form-38 carried a wrongly mentioned amount and column no. 6 was left unfilled; goods were seized and released on security, after which penalty proceedings were initiated.

Patterns across these 12 rulings

Statutory heterogeneity of "Section 54(1)": The most pronounced pattern in this compilation is that the section number "54(1)" appears across at least three distinct statutes — the Income Tax Act 1961, the CGST Act 2017, and the U.P. Value Added Tax Act 2008. Cases 6, 8, and 12 involve penalty proceedings under Section 54(1)(14) of the U.P. VAT Act; cases 2, 3, 4, 5, 7, 9, 10, and 11 engage Section 54(1) of the CGST Act in the context of refund limitation; and case 1 involves Sections 54(1) and 54F of the Income Tax Act in the context of capital-gains exemption. Researchers must identify the governing statute before applying any ratio across cases.
Two-year limitation under CGST Section 54(1) as a recurring dispute ground: Across the CGST cases (cases 9, 10, 11, and 5), the central procedural flashpoint is whether a refund application was filed within two years of the "relevant date" as prescribed by Section 54(1) of the CGST Act. This limitation ground — not the substantive eligibility for refund — appears to have been the basis on which refund claims were rejected at the first and second levels before writ petitions were filed.
Form-38 documentation irregularities in UP VAT interception cases: In cases 6, 8, and 12, the factual pattern involves goods intercepted in transit in Uttar Pradesh, with penalty proceedings initiated under the U.P. VAT Act not because of missing documents per se, but because of specific column-level deficiencies in Form-38 (blank columns, incorrectly filled amounts) — raising questions about the proportionality of penalty to technical documentation lapses.
Writ jurisdiction invoked after appellate remedy exhaustion: Across the CGST refund cases (cases 9, 10, 11), the petitioners had already exhausted at least one level of statutory appeal before approaching the High Court under Articles 226/227. Case 3 presents a variant where the High Court was initially unwilling to entertain a writ petition on the ground of an available alternative remedy under the Gujarat GST Act before proceeding on merits.
Incomplete source extracts limit substantive ratio extraction: In several cases (cases 2, 3, 7), the text_preview available in the source corpus is procedural-header-heavy and does not contain the final operative reasoning or the dispositive direction. Patterns will expand as full authenticated judgments are added to the corpus.

How to use this compilation

This index is a structured starting point for locating primary source documents, not a substitute for reading the full authenticated judgment. Each entry in this compilation should be verified against the complete order as published on the official court portal (indiankanoon.org, the High Court's e-filing/neutral citation portal, or the ITAT's official website) before it is cited in any memo, brief, pleading, or internal note. Pay particular attention to whether a ruling has been stayed, reversed on further appeal, or distinguished in subsequent proceedings — none of which would necessarily be reflected in this index.

When using this compilation for cross-jurisdictional research, always identify the governing statute for the "Section 54(1)" reference in each case before drawing any inference. A ratio on the two-year limitation under Section 54(1) of the CGST Act 2017 has no direct application to the capital-gains exemption under Section 54(1) of the Income Tax Act 1961, and vice versa. Similarly, the U.P. VAT Act's Section 54(1)(14) penalty provisions operate in an entirely different legislative scheme. Cross-statute conflation is a significant research error in this section-number family.

Finally, for matters involving CGST refund limitations or capital-gains exemption conditions, researchers should also check for contemporaneous CBDT Circulars, CBIC Circulars, and any Notifications or clarifications issued under the relevant Act, as these may affect the computation of the "relevant date," extend limitation periods, or modify procedural requirements in ways that are not visible from the judgment text alone. Parallel AAR rulings, if any, on the same statutory question should also be cross-referenced.

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 54(1) Across Tax Regimes: 12 Rulings Index (2022–2026)