This compilation indexes twelve tribunal and High Court rulings decided between June 2024 and July 2026 in which Section 54B of the Income Tax Act, 1961 — the exemption provision for capital gains arising from the transfer of agricultural land used for agricultural purposes — was a central or material issue. The cases span ITAT benches at Ahmedabad, Dehradun, Jabalpur, Nagpur, Patna, Agra, Raipur, and Jodhpur, as well as the Gujarat High Court. It is designed for use by in-house tax teams, Big-4 associates, and law-firm researchers who need a rapid-reference index of live disputes involving Section 54B.

Research index only. This page is a structured case-law reference tool. Nothing on this page constitutes legal or tax advice. Readers must consult the full text of each judgment and qualified counsel before drawing conclusions for any matter.

The statutory framework in one paragraph

Section 54B of the Income Tax Act, 1961, provides an exemption from capital gains arising on the transfer of a capital asset being land which, in the two years immediately preceding the date of transfer, was being used by the assessee or a parent of the assessee for agricultural purposes. The exemption is available to the extent the capital gain is invested in the purchase of another agricultural land within a specified period. If the newly purchased land is transferred within three years of its acquisition, the amount of gain originally exempted is treated as long-term or short-term capital gain of the year of such transfer. Section 2(14) of the Act is also relevant because it governs whether a particular piece of land qualifies as a "capital asset" — agricultural land situated in rural areas is excluded from the definition of "capital asset" under Section 2(14)(iii), whereas land situated within specified municipal or notified limits may qualify, directly affecting whether Section 54B becomes operative at all.

The 12 rulings

1. Shailesh Narshibhai vs Income Tax Officer Ward 1, Himmatnagar

Bench: Income Tax Appellate Tribunal - Ahmedabad
Date: 14 July 2026
Sections engaged: 2(14)(m), 54B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee before ITAT Ahmedabad (ITA No. 2382/AHD/2025) for Assessment Year 2011-12, against the order of the Commissioner of Income Tax (Appeals) dated 29.03.2019, which had arisen from proceedings under the Act. The source preview notes a delay of 2376 days in filing the appeal, making condonation of delay a significant procedural question before the Tribunal; the substantive dispute engages Sections 2(14)(m) and 54B of the Act.

2. Deputy Commissioner Of Income Tax vs Rajesh Jain, Rajpur Road, Dehradun

Bench: Income Tax Appellate Tribunal - Dehradun
Date: 15 May 2026
Sections engaged: 54B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 1/DDN/2026) concerns Assessment Year 2016-17 and was filed by the Revenue against the assessee. Per the source preview, the assessee had declared taxable income of Rs. 40,70,830/- for AY 2016-17, earning Long Term Capital Gain on the sale of certain property, and had claimed exemptions under Section 54B (along with other provisions) of the Act; the case was selected for scrutiny and the Revenue's appeal before ITAT Dehradun challenges the allowance of the claimed exemptions.

3. Prakash Sharma, Nainpur vs Income Tax Officer, Mandla

Bench: Income Tax Appellate Tribunal - Jabalpur
Date: 13 May 2026
Sections engaged: 50C, 54B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 3/JAB/2024) relates to Assessment Year 2012-13. Per the source preview, the assessee sold immovable property on 15.11.2011 for a stated consideration of Rs. 30,000/-, while the Stamp Valuation Authority computed the value at Rs. 6,17,000/-; accordingly, the Assessing Officer applied Section 50C and also found that no capital gain from the sale had been disclosed by the assessee in the return, which declared only business income of Rs. 2,61,972/-. The assessment was reopened and a notice under Section 148 was issued, with Section 54B also arising in the context of the capital gains dispute.

4. Fattesing Punaji Dhabre, Nagpur vs Principal Commissioner Income Tax – 2

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 24 February 2026
Sections engaged: 50C, 54B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 368/NAG/2022) was filed by the assessee against the order of the Principal Commissioner of Income Tax-2, Nagpur dated 30/03/2021 for Assessment Year 2011-12. Per the source preview, the dispute involved the application of Section 50C — with an apparent difference between the consideration adopted for stamp duty purposes and the consideration otherwise applicable — alongside the Section 54B exemption claim; an additional ground of appeal was also raised by the assessee vide application dated 26.08.2024.

5. Harihar Prasad, Patna vs ITO Ward 4 (4), Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 20 November 2025
Sections engaged: 54B, 54F, 2(47)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 268/PAT/2023) was filed by the assessee against the order of the CIT(Appeals)-NFAC, Delhi dated 08.08.2023 for Assessment Year 2017-18. Per the source preview, the assessee had filed a return of income showing total income of ₹5,88,940/- and the case was selected for scrutiny under CASS because the assessee had claimed a large exemption under Section 54B; the assessee had a piece of land in village Saidanpur (Mau), Hilsa which was the subject of the capital gains dispute, with Sections 54F and 2(47) also engaged.

6. Bhagvan Das L/H Shri Gauri vs ITO Ward 2(2)(1), Firozabad

Bench: Income Tax Appellate Tribunal - Agra
Date: 30 October 2025
Sections engaged: 54B, 271(1)(c)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two appeals (ITA No. 260 & 259/Agr/2025) were preferred by the assessee for Assessment Year 2012-13 against separate orders dated 24.06.2024 of the CIT(Appeals)-NFAC, Delhi. Per the source preview, the CIT(A) had dismissed the assessee's appeals — confirming both the assessment order dated 29.09.2017 passed under the Act and a penalty order dated 19.03.2018 under Section 271(1)(c) — on the ground that the assessee's Section 54B claim had not been accepted; the combined appeal before ITAT Agra challenges both the assessment and the penalty.

7. Sampat Lal Jhabak, Raipur vs Principal Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Raipur
Date: 19 February 2025
Sections engaged: 54B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 478/RPR/2024) was filed by Sampat Lal Jhabak for Assessment Year 2013-14 against the Principal Commissioner of Income Tax-1, Raipur, and was heard alongside a batch of related appeals filed by other members of the Jhabak family — all pertaining to the same assessment year and the same respondent authority. The source preview indicates the dispute before ITAT Raipur centrally involved the Section 54B exemption claim; the full reasoning of the order is not available in the source preview.

8. Kamala Chandrakar, Durg vs Principal Commissioner Of Income Tax

Bench: Income Tax Appellate Tribunal - Raipur
Date: 21 November 2024
Sections engaged: 54B
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 215/RPR/2024) was filed by the assessee for Assessment Year 2012-13 against the Principal Commissioner of Income Tax, Raipur-1. Per the source preview, the capital gains computation shown in the order reflects: sale consideration of Rs. 1,19,40,000/-, less purchase cost of Rs. 49,78,194/-, yielding a capital gain of Rs. 69,61,806/-, against which an exemption under Section 54B of Rs. 52,18,062/- was claimed, resulting in taxable capital gain of Rs. 17,43,744/-; the appeal before ITAT Raipur relates to the correctness of this Section 54B exemption computation.

9. Arun Agarwal, Jodhpur vs ITO, Ward-1(2), Bikaner

Bench: Income Tax Appellate Tribunal - Jodhpur
Date: 23 September 2024
Sections engaged: 54B, 50C
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 60/Jodh/2024) was filed by the assessee for Assessment Year 2013-14 against the appellate order of the National Faceless Appeal Centre (NFAC), Delhi dated 08.01.2024, which had dismissed the assessee's appeal against the assessment order passed under the Act dated 28.03.2016 by the Income Tax Officer, Ward-1(2), Bikaner. The assessee, aggrieved by the NFAC order, approached ITAT Jodhpur; Sections 54B and 50C are both engaged in the dispute.

10. Sushila Bhaurao Deshmukh, Amravati vs Principal Commissioner Of Income

Bench: Income Tax Appellate Tribunal - Nagpur
Date: 20 September 2024
Sections engaged: 263, 54B, 54E
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 76/Nag./2022) was filed by the assessee for Assessment Year 2017-18 against the Principal Commissioner of Income Tax, Nagpur, in the context of a revision proceeding under Section 263 of the Act. Per the source preview, the assessee had produced an extensive set of documents before the authorities including the assessment order, notices, sale deed dated 22/03/2017, purchase deed dated 23/06/2017, bank statements, and capital gain computations reflecting claims under Sections 54B and 54E; the revisional jurisdiction of the PCIT under Section 263 is the primary procedural vehicle in this matter.

11. Kiritbhai Parshottambhai Patel vs The Assistant Commissioner Of Income

Bench: Gujarat High Court
Date: 30 August 2024
Sections engaged: 148, 54B, 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: The petition (R/Special Civil Application No. 5357 of 2022) was filed under Article 226 of the Constitution of India before the Gujarat High Court, challenging a notice under Section 148 of the Act dated 31.03.2021 by which the revenue sought to reopen the assessment for Assessment Year 2015-16. Per the source preview, the petitioner had filed a return of income on 17.03.2016 declaring income of Rs. 4,71,910/-, wherein capital gain on sale of agricultural land was disclosed and a deduction of Rs. 65,95,762/- was claimed under the relevant section; the validity of the Section 148 reopening notice, in the context of the Section 54B and 54F claims, is the core issue before the High Court.

12. Nikita Jenishkumar Patel vs The Income Tax Officer Ward 1(3)(8)

Bench: Gujarat High Court
Date: 14 June 2024
Sections engaged: 50C, 54B
Outcome: Outcome not specified in source
Procedural / substantive ground: The matter (R/Special Civil Application No. 22045 of 2019, heard with SCA No. 22046 of 2019) came before the Gujarat High Court as a writ petition. Per the source preview, the dispute involved a difference of Rs. 2,34,29,056/- between the sale consideration declared by the assessee and the value otherwise computed, indicating a Section 50C applicability question alongside the Section 54B exemption claim; the High Court examined the intersection of these two provisions in the context of the challenge raised by the petitioner.

Patterns across these 12 rulings

Section 50C and Section 54B frequently arise together. Four of the twelve rulings (cases 3, 4, 9, and 12) engage both Section 50C (stamp duty valuation substitution) and Section 54B simultaneously, suggesting that disputes where the Stamp Valuation Authority's value exceeds stated consideration commonly trigger a second-order question about whether the resulting capital gain is sheltered by the Section 54B exemption.
Revision under Section 263 and Section 54B interact. Two cases (cases 4 and 10) involve Principal Commissioner-initiated proceedings — one framed as a Section 263 revision (case 10) and one framed as an appeal against a PCIT order (case 4) — reflecting a pattern where the PCIT exercises revisionary jurisdiction specifically to examine whether the Section 54B exemption was correctly allowed at the assessment stage.
Reassessment notices under Section 148 are challenged where Section 54B was already disclosed. Case 11 illustrates a writ petition at the High Court level challenging a Section 148 reopening notice for an assessment year in which the Section 54B deduction had been affirmatively declared in the original return, raising questions about the sufficiency of "reason to believe" where the exemption claim was not concealed.
Penalty under Section 271(1)(c) follows disallowance of Section 54B. Case 6 demonstrates a pattern where the disallowance of the Section 54B exemption at the assessment stage is followed by a penalty order, leading to a combined challenge before the Tribunal on both quantum and penalty grounds.
Significant delays in filing appeals are noted. Case 1 records a delay of 2376 days in filing the appeal before ITAT Ahmedabad, illustrating that Section 54B disputes from older assessment years (here, AY 2011-12) continue to enter the appellate system with substantial procedural delay, making condonation a threshold issue before the substantive ground is reached.

How to use this compilation

This index is intended as a first-pass research tool. Each entry provides the identity fields — bench, date, sections engaged, and outcome direction — drawn verbatim from the structured legal corpus, and a brief procedural note drawn from the available source preview. Researchers should treat these entries as pointers to the full judgment text rather than as summaries of the final holding: because the outcome_direction field for all twelve cases is recorded as "Outcome not specified in source," the dispositive direction of each order (allowed, dismissed, remanded, or partly allowed) must be verified against the complete judgment text obtained from indiankanoon.org or the relevant official court portal.

Before relying on any ruling indexed here, researchers should check whether the order has been stayed, reversed, or affirmed in subsequent appellate proceedings. ITAT orders may have been challenged before the High Court; High Court orders may be pending before the Supreme Court. Where a case involves both a quantum appeal and a penalty appeal (as in case 6), the outcomes of the two limbs may differ and must be tracked separately. Researchers should also check for any CBDT circulars or instructions issued under Section 119 that may affect the operation of Section 54B for the relevant assessment years, as administrative guidance can affect the positions taken by the department independently of judicial rulings.

Assessment years in this compilation range from AY 2011-12 to AY 2017-18, and the orders themselves were pronounced between June 2024 and July 2026. The vintage of the underlying transactions means that the applicable statutory text of Section 54B, the prevailing stamp duty valuation rules, and the procedural reassessment regime operative at the time of the original assessment must be verified for each case individually, as amendments to these provisions over time may affect the applicability of reasoning from one case to another.

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 54B Agricultural Land Exemption: 12 ITAT & HC Rulings (2024–2026)