This compilation indexes twelve income-tax adjudications — eleven ITAT orders and one Karnataka High Court division bench judgment — in which Section 54F of the Income-Tax Act, 1961 was a substantive issue. The cases span Assessment Years 2010-11 through 2023-24 and were pronounced between November 2025 and July 2026 across tribunals in Hyderabad, Delhi, Jaipur, Bangalore, Chennai, Vizag, Lucknow, Kolkata, Surat, and Patna, as well as the Karnataka High Court. The compilation is intended for use by in-house tax teams, Big-4 associates, and law firm researchers who need a rapid cross-jurisdictional survey of live Section 54F litigation.

Research index only. This page is a structured case-law reference compiled from publicly available tribunal and court orders. Nothing on this page constitutes legal or tax advice. Readers should consult the full text of each judgment and verify current status before relying on any ruling.

The statutory framework in one paragraph

Section 54F of the Income-Tax Act, 1961 provides an exemption from long-term capital gains tax to an individual or Hindu Undivided Family (HUF) who sells any long-term capital asset (other than a residential house) and invests the net consideration in the purchase or construction of one residential house property in India, subject to conditions including timelines for investment, restrictions on ownership of more than one residential house on the date of transfer, and compliance with lock-in requirements for the new asset. The section sets out proportionate exemption where the entire net consideration is not reinvested, and contains provisions for withdrawal of the exemption if the new asset is transferred or additional residential properties are acquired within specified periods.

The 12 rulings

1. Rajeshwer Reddy Thimmannagari,Medak vs ITO, Ward-1, Sangareddy

Bench: Income Tax Appellate Tribunal - Hyderabad
Date: 1 July 2026
Sections engaged: 147, 148, 50C, 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal was filed by the assessee against the order of the Commissioner of Income Tax (Appeals), National Faceless Appeal Centre (NFAC), Delhi dated 23.10.2025 for Assessment Year 2018-19 (ITA No. 2314/Hyd/2025). Per the source preview, the assessee, an individual, had not filed any return of income for Assessment Year 2018-19, and the Assessing Officer initiated proceedings based on information available to it regarding transactions during the year under consideration.

2. Sushma Kapur,Delhi vs ITO, NFAC

Bench: Income Tax Appellate Tribunal - Delhi
Date: 1 July 2026
Sections engaged: 143(3), 54, 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 7294/Del/2025) was filed by the assessee against the order of CIT(A)-NFAC-Delhi dated 29.09.2025 arising from the assessment order dated 23.09.2022 passed by NFAC, Delhi under Section 143(3) r.w.s 144B of the Income Tax Act, 1961 for Assessment Year 2020-21. The assessee's grounds prayed for deletion of additions/disallowances characterised as illegal, without firm basis, and founded on presumptions, per the source preview.

3. Abdul Aziz,Jaipur vs ITO Wd 1(2), Jpr, Jaipur

Bench: Income Tax Appellate Tribunal - Jaipur
Date: 30 June 2026
Sections engaged: 250, 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter was heard as part of a batch of four appeals (ITA Nos. 1134, 1136, 1138, and 1143/JPR/2025) all relating to Assessment Year 2010-11, filed by individual appellants including Abdul Aziz, before the SMC Bench at Jaipur. Per the source preview, the appeals were filed against ITO Ward 1(1), Jaipur, and were heard on 03.06.2026 with pronouncement on 30.06.2026.

4. Parthasarathy Venkates vs Income-Tax Officer, Ward - 3(1)(1)

Bench: Income Tax Appellate Tribunal - Bangalore
Date: 29 June 2026
Sections engaged: 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: This appeal (ITA No. 1121/Bang/2026) relates to Assessment Year 2015-16 and was directed against the appellate order of the National Faceless Appeal Centre, Delhi dated 16 March 2026, which had dismissed the assessee's appeal against a reassessment order dated 7 February 2023. Per the source preview, the Revenue had received information that the assessee sold immovable property for ₹1,28,15,000 but had not filed a return of income for Assessment Year 2015-16; the assessee subsequently filed a return in response to notice proceedings and declared the sale consideration.

5. Katragadda Bhavani vs ITO, Ncw-1(1), Coimbatore

Bench: Income Tax Appellate Tribunal - Chennai
Date: 8 June 2026
Sections engaged: 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (ITA No. 4064/Chny/2025) arises from the order of CIT(A)-NFAC dated 19.11.2025 for Assessment Year 2023-24, passed against the Assessing Officer's order under Section 143(3) r.w.s 144B of the Income Tax Act, per the source preview. The appeal was heard on 13.05.2026 and pronounced on 08.06.2026.

6. Siva Brahma Narayana Chowdary vs The ACIT, Central Circle, Vijayawada

Bench: Income Tax Appellate Tribunal - Vizag
Date: 13 May 2026
Sections engaged: 54F, 143(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: Per the source preview, the assessee, a Doctor by profession and Managing Director of M/s. Vignesh Super Specialty Hospitals Private Limited, also operated a pharmacy under the name M/s. Vignesh Medicals, and had filed his return of income for AY 2018-19 on 31/07/2018 declaring an income of Rs. 27,21,230/-; the return was initially processed under Section 143(1). A survey under Section 133A was subsequently conducted on the hospital entity on 21/03/2019, after which further proceedings followed (ITA No. 13/Viz/2026).

7. Meenu Malhotra,Kanpur vs Income Tax Officer, NFAC, Delhi

Bench: Income Tax Appellate Tribunal - Lucknow
Date: 10 April 2026
Sections engaged: 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: Per the source preview, the assessee filed an original return of income for Assessment Year 2013-14 on 31.07.2013 declaring a total income of Rs. 24,97,360/-, and subsequently filed a revised return on 31.05.2014 declaring Rs. 2,82,680/-, claiming exemption under Section 54F amounting to Rs. 23,59,223/-; the Assessing Officer denied the exemption while completing scrutiny assessment (ITA No. 59/LKW/2025), and the present appeal was preferred against the NFAC order dated 09.05.2024.

8. Zafar Iqbal,Siliguri vs DCIT, Circle - 1, Siliguri, Siliguri

Bench: Income Tax Appellate Tribunal - Kolkata
Date: 5 February 2026
Sections engaged: 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: Per the source preview (ITA No. 1170/KOL/2024, Assessment Year 2016-17), the order records detailed capital gain computation particulars including the cost of acquisition of 2.81 acres of land received as a gift on 1.2.2006 from the appellant's brother (original cost in the brother's hands as on 25.5.1990 at Rs. 12,000/-), additional land purchase costs, cost of improvement of Rs. 55,71,982/-, long-term capital gain of Rs. 44,63,518/-, and reinvestment into a new house property with total cost components including stamp duty, occupant tenant payments, and lawyer's fees aggregating Rs. 3,13,62,500/-.

9. Income Tax Officer vs Narayan Ravi Prakash

Bench: Karnataka High Court
Date: 27 January 2026
Sections engaged: 54F, 148
Outcome: Outcome not specified in source
Procedural / substantive ground: This matter (Writ Appeal No. 17 of 2025, NC: 2026:KHC:4308-DB) was filed by the Income Tax Officer before a Division Bench of the Karnataka High Court seeking to set aside the order dated 06/08/2024 passed by a learned Single Judge in Writ Petition No. 8936/2022 (T-IT). Per the source preview, the Division Bench's oral judgment addressed issues relating to deduction/exemption from capital gain and investment in immovable property in both regular assessment and reassessment contexts.

10. Arun Kumar Gupta, Income Tax vs Asodaria Gordhanbhai Ranchhodbhai

Bench: Income Tax Appellate Tribunal - Surat
Date: 29 December 2025
Sections engaged: 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: This revenue appeal (ITA No. 601/SRT/2023, AY 2017-18) emanated from the order passed under Section 250 of the Act by CIT(A)-NFAC, Delhi dated 03.07.2023, per the source preview. The tribunal noted that all grounds raised by the revenue were inter-related and pertained to the correctness of the deduction under Section 54F, and took them up together for adjudication for clarity and convenience.

11. 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: Per the source preview (ITA No. 268/PAT/2023, Assessment Year 2017-18), the assessee, an individual, had filed a return showing total income of ₹5,88,940/- which was selected for scrutiny under Computer Assisted Scrutiny Selection (CASS) because the assessee had claimed large exemption under Section 54B; the assessee held a piece of land in village Saidanpur (Mau), Hilsa. The appeal was filed against the CIT(A)-NFAC order dated 08.08.2023 passed under Section 250.

12. Kripa Shanker,Patna vs Income Tax Officer, Ward 4(1), Patna

Bench: Income Tax Appellate Tribunal - Patna
Date: 12 November 2025
Sections engaged: 250(6), 54F
Outcome: Outcome not specified in source
Procedural / substantive ground: Per the source preview (ITA No. 117/PAT/2025, Assessment Year 2014-15), the Registry noted the appeal was barred by limitation by 558 days; the assessee filed a condonation petition explaining that the order under Section 250 was never served upon him — neither to his e-mail nor by SMS — and the tribunal, on perusing the petition, was satisfied that the assessee had a reasonable and sufficient cause for the delay. The underlying appeal was against the CIT(A)-NFAC order dated 26.06.2023.

Patterns across these 12 rulings

Widespread NFAC routing. Across the majority of these cases, the first appellate authority whose order is under challenge before the ITAT is the Commissioner of Income Tax (Appeals) at the National Faceless Appeal Centre (NFAC), Delhi — reflecting the near-universal channelling of appellate proceedings through the faceless regime regardless of the assessee's jurisdiction.
Non-filing and reassessment as a recurring trigger. In at least two cases visible from the previews (cases 1 and 4), proceedings were initiated because the assessee had not filed a return of income for the relevant year despite receiving sale consideration from immovable property, with the Revenue acting on third-party information before invoking reassessment procedures.
Revenue-side appeals on Section 54F deductions. Case 10 (ITAT Surat) illustrates that the Revenue itself files appeals before the ITAT challenging CIT(A) orders that allowed Section 54F deductions, indicating that the exemption remains actively contested from the department's side and is not solely an assessee-driven issue.
Limitation and procedural condonation issues co-existing with substantive 54F claims. Case 12 (ITAT Patna) shows that Section 54F appeals can carry significant procedural complications — in that instance a delay of 558 days — arising from alleged non-service of the first appellate order, which the tribunal had to resolve as a threshold question before reaching the merits.
Multi-section intersection. Several cases engage Section 54F alongside other provisions: reassessment sections (cases 1, 4, 9), stamp duty valuation provisions (case 1), Section 54B in the same appeal (case 11), and scrutiny assessment provisions (cases 2, 5, 6). This reflects the practical reality that Section 54F disputes rarely arise in isolation and commonly intersect with how the underlying transfer is characterised, valued, or discovered.

How to use this compilation

This index is a starting point for identifying live Section 54F litigation across Indian tribunals and high courts. Each entry provides the ITA or writ appeal number (where visible in the source preview), the Assessment Year, the bench, and the date of pronouncement so that a researcher can locate the full text of the order on indiankanoon.org, the ITAT's official e-filing portal, or the relevant high court's case status system. Because the source previews in several cases are limited to procedural headers and opening paragraphs, the substantive reasoning — findings on eligibility conditions, proportionate exemption calculations, or the specific ground on which relief was granted or denied — must be read from the complete judgment text before any reliance is placed.

Researchers should also verify whether any of these orders have been appealed further. An ITAT order may be the subject of a pending High Court writ, appeal under Section 260A, or a Special Leave Petition before the Supreme Court. Similarly, an order at the High Court level (as in case 9) may have been further challenged or may have attained finality. Checking the current litigation status is an essential step before treating any ruling as settled authority.

Finally, practitioners should cross-reference applicable CBDT circulars, instructions, and notifications bearing on Section 54F conditions — including any clarifications on deposit in the Capital Gains Accounts Scheme, construction timelines, or the definition of residential house — since departmental positions articulated in circulars may bear on how the section is applied in a given assessment year.

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 54F Capital Gains Exemption: 12 ITAT & HC Rulings (2025–2026)