CIT v. D. Ananda Basappa

309 ITR 329High Court2009#1181 most cited

What is CIT v. D. Ananda Basappa authority for?

For exemption under Section 54, the expression 'a residential house' allows for investment in multiple residential units that form one functional unit, as 'a' does not imply a singular number. The amendment to Section 54, effective from April 1, 2015, is prospective.

97

judgments rely on this decision, according to BharatTax’s citation analysis of 292,668 Indian tax judgments — from 2013 to 2025.

Also referred to as

CIT v. D. Ananda Basappa · 309 ITR 329 · Section 54 exemption · investment in more than one residential house · meaning of "a residential house" · Section 13(2) General Clauses Act · clubbing adjacent apartments · Section 54 amendment prospective

Also reported as

180 Taxmann 443 Taxmann.com 143

Sections most often in play

Section 54FSection 234BSection 54Section 143(3)Section 234ASection 234CSection 46ASection 13(2) of the General Clauses Act

Issues it is cited on

section 54(1)section 13(2)long-term capital assetjoint development agreementsection 54fjdasection 54date of transferindexed cost of acquisitionsection 45fair market valuelong term capital gain

Judgments citing CIT v. D. Ananda Basappa

JYOTI JAIN,NEW DELHI vs. DCIT, CIRCLE-19(2), NEW DELHI

In the result, ground no. 5 of appeal is allowed for statistical purpose

ITA 4983/DEL/2018[2014-15]Status: DisposedITAT Delhi23 Sept 2025AY 2014-15

Bench: Shri Vikas Awasthy & Shri M. Balaganeshआअसं.4983/िद"ी/2018 (िन.व. 2014-15) Jyoti Jain, 25/94, Shakti Nagar, New Delhi 110007 ...... अपीलाथ"/Appellant Pan No: Adipj-0775-G बनाम Vs. Deputy Commissioner Of Income Tax, ..... "ितवादी/Respondent Circle 19(2), New Delhi

For Appellant: Shri Nirbhay Mehta & Ms. Vanshika Mehta, AdvocatesFor Respondent: Shri Om Prakash, Sr. DR
Section 54F

…the family members of the Assessee. The fact that different floors may be owned or partly owned would not detract from the fact that the portions owned were required to be considered 'one residential house'. 20. In CIT v. D. Ananda Basappa [2009] 180 Taxman 4/309 ITR 329 (Karnataka), the Karnataka High Court considered the admissibility of exemption under Section 54 of the Act in a case where the Assessee had sold a residential house and purchased two adjacent apartments. The Court held that "the expression 'a' residential house should be understood in a sense that building should be of residential in nature and…

THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 vs. LATA GOEL

ITA/127/2025HC Delhi30 Apr 2025

Bench: The Learned

Section 132Section 143(3)Section 147Section 148Section 153ASection 260ASection 54F

…f the Assessee. The fact that different floors may be owned or partly owned would not detract from the fact that the portions owned were required to be considered ‘one residential house’. 20. In Commissioner of Income-tax and Anr. v. D. Ananda Basappa: (2009) 309 ITR 329, the Karnataka High Court considered the admissibility of exemption under Section 54 of the Act in a case where the Assessee had sold a residential house and purchased two adjacent apartments. The Court held that “the expression ‘a’ residential house should be understood in a sense that building should be of residential in nature and ‘a’ should n…

THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 vs. LATA GOEL

ITA-127/2025HC Delhi30 Apr 2025

Bench: The Learned

Section 132Section 143(3)Section 147Section 148Section 153ASection 260ASection 54F

…f the Assessee. The fact that different floors may be owned or partly owned would not detract from the fact that the portions owned were required to be considered ‘one residential house’. 20. In Commissioner of Income-tax and Anr. v. D. Ananda Basappa: (2009) 309 ITR 329, the Karnataka High Court considered the admissibility of exemption under Section 54 of the Act in a case where the Assessee had sold a residential house and purchased two adjacent apartments. The Court held that “the expression ‘a’ residential house should be understood in a sense that building should be of residential in nature and ‘a’ should n…

THE PR. COMMISSIONER OF INCOME TAX -CENTRAL -1 vs. LATA GOEL

ITA - 127 / 2025HC Delhi30 Apr 2025

Bench: The Learned

Section 132Section 143(3)Section 147Section 148Section 153ASection 260ASection 54F

…f the Assessee. The fact that different floors may be owned or partly owned would not detract from the fact that the portions owned were required to be considered ‘one residential house’. 20. In Commissioner of Income-tax and Anr. v. D. Ananda Basappa: (2009) 309 ITR 329, the Karnataka High Court considered the admissibility of exemption under Section 54 of the Act in a case where the Assessee had sold a residential house and purchased two adjacent apartments. The Court held that “the expression ‘a’ residential house should be understood in a sense that building should be of residential in nature and ‘a’ should n…

SANJEEV BEHL ,MUMBAI vs. INCOME TAX OFFICER INT TAX WARD, 1(2)(1), MUMBAI

In the result, the appeal by the assessee is allowed

ITA 5345/MUM/2024[2016-17]Status: DisposedITAT Mumbai30 Apr 2025AY 2016-17
For Appellant: Shri K GopalFor Respondent: Shri Vijaykumar G Subramanyam, Sr.DR
Section 10Section 144C(3)Section 147Section 148Section 2(24)Section 250Section 56Section 80

…ial house' as occurring in section 54 can include more than one or\nplural residential house. While deciding so the ITAT, Mumbai has relied upon\nthe decisions in the case of Tilokchand & Sons v. ITO [2019] 413 ITR 189\n(Mad.), CIT v. D. Ananda Basappa [2009] 309 ITR 329 (Kar), CIT v.\nKhoobchand M. Makhija [2014] 223 Taxman 189 (Kar) and CIT v. Gunamal\nJain [2017] 394 ITR 666 (Mad).\nIn the case of the appellant, the appellant has sold two residential\nproperties on 18.02.2016, therefore, benefit u/s 54 could not be given to the\nappellant.\n7.3.5 The A.O. called for information u/s.133(6) from the builder and…

The Commissioner of Income Tax(Central) vs. M/s.Madhu Enterprises

ITTA/127/2025HC Telangana12 Feb 2025

Bench: The Learned

Section 132Section 143(3)Section 147Section 148Section 153ASection 260ASection 54F

…f the Assessee. The fact that different floors may be owned or partly owned would not detract from the fact that the portions owned were required to be considered ‘one residential house’. 20. In Commissioner of Income-tax and Anr. v. D. Ananda Basappa: (2009) 309 ITR 329, the Karnataka High Court considered the admissibility of exemption under Section 54 of the Act in a case where the Assessee had sold a residential house and purchased two adjacent apartments. The Court held that “the expression ‘a’ residential house should be understood in a sense that building should be of residential in nature and ‘a’ should n…

ACIT, CIRCLE-24(1), MUMBAI, MUMBAI vs. NAKUL AGGARWAL, MUMBAI

In the result the appeal filed by the assessee stands allowed and appeal filed by the revenue stands dismissed

ITA 2833/MUM/2024[2017-18]Status: DisposedITAT Mumbai14 Oct 2024AY 2017-18

Bench: Smt. Beena Pillai () & Smt.Renu Jauhri ()

Section 250Section 253(1)(a)Section 54F

…1 ITA No.2833 /Mum/2024 ITA No.2551 /Mum/2024 Nakul Aggarwal IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B”, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) AND SMT.RENU JAUHRI (ACCOUNTANT MEMBER) I.T.A. No.2551/Mum/2024 (Assessment year 2017-18) Nakul Aggarwal vs Assistant Commissioner of 1401, D N Nagar, Terra Wing Income Tax, Circle-24(1), C Mumbai Rustomjee Elements 601, Piramal Chambers, Andheri (W), Mumbai-400 Lalbaug, Parel, Mumbai-400 053 012 PAN : AIYPA3923A APPELLANT RESPONDENT I.T.A. No.2833/Mum/2024 (Assessment year 2017-18) ACIT, CIRCLE-24(1), Mumbai vs Nakul Aggarwal 601, Piramal Chambers…

NAKUL AGGARWAL,MUMBAI vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-24(1), MUMBAI

In the result the appeal filed by the assessee stands allowed and appeal filed by the revenue stands dismissed

ITA 2551/MUM/2024[2017-18]Status: DisposedITAT Mumbai14 Oct 2024AY 2017-18

Bench: Smt. Beena Pillai () & Smt.Renu Jauhri ()

Section 250Section 253(1)(a)Section 54F

…1 ITA No.2833 /Mum/2024 ITA No.2551 /Mum/2024 Nakul Aggarwal IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “B”, MUMBAI BEFORE SMT. BEENA PILLAI (JUDICIAL MEMBER) AND SMT.RENU JAUHRI (ACCOUNTANT MEMBER) I.T.A. No.2551/Mum/2024 (Assessment year 2017-18) Nakul Aggarwal vs Assistant Commissioner of 1401, D N Nagar, Terra Wing Income Tax, Circle-24(1), C Mumbai Rustomjee Elements 601, Piramal Chambers, Andheri (W), Mumbai-400 Lalbaug, Parel, Mumbai-400 053 012 PAN : AIYPA3923A APPELLANT RESPONDENT I.T.A. No.2833/Mum/2024 (Assessment year 2017-18) ACIT, CIRCLE-24(1), Mumbai vs Nakul Aggarwal 601, Piramal Chambers…

VIVEK GANGADHAR MEHENDALE,SANTACRUZ, MUMBAI vs. INCOME TAX OFFICER,WARD 22(3)(1),, PIRAMAL CHAMBERS,MUMBAI

In the result, the appeal of the assessee bearing ITA No

ITA 2644/MUM/2024[2014-15]Status: DisposedITAT Mumbai07 Oct 2024AY 2014-15

Bench: Shri Anikesh Banerjee & Miss Padmavathy S.

For Appellant: ShriAnil SatheFor Respondent: Ms. Rajeshwari Menon, SRDR
Section 139(1)Section 143(3)Section 147Section 148Section 250Section 54Section 54FSection 64(1)

…IN THE INCOME TAX APPELLATE TRIBUNAL MUMBAI BENCH “F”, MUMBAI BEFORE SHRI ANIKESH BANERJEE, JUDICIAL MEMBER AND MISS PADMAVATHY S., ACCOUNTANT MEMBER I.T.A. 2644/Mum/2024 (Assessment Year: 20141-15) Vivek Gangadhar Mehendale vs Income Tax Officer, Ward 22(3)(1), 502, New Shobhna CHS Piramal Chambers, Mumbai SaratchandraChatterjee Marg, Santacruz, Mumbai-400054 PAN:AAOPM2002L APPELLANT RESPONDENT Assessee by : ShriAnil Sathe Respondent by : Ms. Rajeshwari Menon, SRDR Date of hearing : 30/09/2024 Date of pronouncement : 07/10/2024 O R D E R PER ANIKESH BANERJEE, J.M: Instant appeal of the assessee was filed…

RAJENDRA AGRAWAL,DELHI vs. ITO WARD-30(2) , DELHI

In the result, the appeal is allowed

ITA 2272/DEL/2024[2012-13]Status: DisposedITAT Delhi26 Jul 2024AY 2012-13

Bench: BEFORESHRI VIKAS AWASTHY (Judicial Member), SHRI AVDHESH KUMAR MISHRA (Accountant Member)

Section 143(3)Section 263Section 54

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘F’: NEW DELHI BEFORESHRI VIKAS AWASTHY, JUDICIAL MEMBER AND SHRI AVDHESH KUMAR MISHRA, ACCOUNTANT MEMBER ITA No.2272/Del/2024, A.Y. 2012-13 Sh. Rajendra Agrawal ITO, C/o. Raj Kumar Associates, Ward-30(2), Chartered Accountants L7A, Vs. Delhi LGF, South Ext. Part-II, Delhi PAN: ACRPA4020F (Appellant) (Respondent) Appellant by Shri Raj Kumar, CA & Sh. Suraj Gupta, Advocate Respondent by Sh. P. N. Barnwal, CIT-DR Date of Hearing 26/06/2024 Date of Pronouncement 26/07/2024 ORDER PER AVDHESH KUMAR MISHRA, AM This appeal for the Assessment Year (In Short, the ‘AY’)…

ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-4(1)(1), BANGALORE vs. SH. NARAYANAPPA RAMANNA, BANGALORE

In the result, appeal filed by the Revenue is dismissed

ITA 691/BANG/2023[2008-09]Status: DisposedITAT Bangalore16 Apr 2024AY 2008-09

Bench: Shri George George K & Shri Laxmi Prasad Sahuassessment Year : 2008-09 Acit, Vs. Shri Narayanappa Ramanna, Circle – 4(1)(1), 1 B, Narayanapur Village, Bengaluru. K. R. Puram Hobli, Bengaluru – 560 016. Pan : Afmpr 3833 C Appellant Respondent Revenue By : Shri. Subramanian S, Jcit(Dr)(Itat), Bengaluru. Assessee By : Shri. Ganesh S, Advocate. Date Of Hearing : 16.04.2024 Date Of Pronouncement : 16.04.2024

For Appellant: Shri. Ganesh S, AdvocateFor Respondent: Shri. Subramanian S, JCIT(DR)(ITAT), Bengaluru
Section 143(3)Section 250Section 54Section 54F

…" and "lands" and, therefore, the singular "a residential house" also permits use of plural by virtue of section 13(2) of the General Clauses Act. A similar view was taken by the Hon'ble Karnataka High Court in the case of D. Ananda Basappa v. ITO reported in 309 ITR 329 (Kar.). 8. Further, the amendment to section 54 of the Act with effect from 01.04.2015 has been held to be prospective by the Hon'ble Karnataka High Court in the case of Arun K. Thiagarajan (supra). The relevant finding of the Hon'ble jurisdictional High Court in the case of Arun K. Thiagarajan (supra), reads as follows:- "12. A Bench of this c…

FAROOQ ABDULLA MERCHANT,MUMBAI vs. ITO 23 (1)(4), MUMBAI

In the result, Ground No. V raised by the assessee is partly allowed

ITA 7906/MUM/2019[2014-15]Status: DisposedITAT Mumbai02 May 2023AY 2014-15

Bench: Shri S. Rifaur Rahman, Hon'Ble & Ms. Kavitha Rajagopal, Hon'Blefarooq Abdulla Merchant V. Income Tax Officer- Ward – 23(1)(4) Matru Mandir, Tardev Road A-1401, Poseidon Tower Mumbai – 400 007 Versova, Yari Road Above Indian Bank, Versova Andheri (W), Mumbai - 400061 Pan: Ahupm7426K (Appellant) (Respondent) Assessee Represented By : Shri Vimal Punamiya Department Represented By : Smt. Vranda U. Matkarni

Section 143(2)Section 54Section 54(1)

…ntial purpose and the amendment brought in the statute w.e.f. 01.04.2015 is not retrospective. Prior to the amendment, there were various judgments wherein favourable view has been taken by the Hon’ble High Courts, viz.,:-  CIT & ANR. vs. D. ANANDA BASAPPA - 309 ITR 329 (Karnataka High Court) Capital gains-Exemption under s. 54- investment in more than one residential units/houses - Expression "a residential house" should be understood in a sense that the building should be or residential nature and "a" should not be understood to indicate a singular number- That apart, the apartments purchased by the assessee a…

ANU GERA,NEW DELHI vs. ITO, NEW DELHI

Accordingly Ground No. 3 of the Assessee is allowed

ITA 2626/DEL/2017[2009-10]Status: DisposedITAT Delhi05 Apr 2023AY 2009-10

Bench: Dr. B.R.R. Kumar & Shri Yogesh Kumar Us

For Appellant: Ms. Rano Jain, Advocate &For Respondent: Shri Kanv Bali, Sr. D. R
Section 143(1)Section 45Section 54

…IN THE INCOME TAX APPELLATE TRIBUNA [ DELHI BENCH: ‘A’ NEW DELHI ] BEFORE Dr. B.R.R. KUMAR, ACCOUNTANT MEMBER AND SHRI YOGESH KUMAR US, JUDICIAL MEMBER I.T.A. No. 2626/DEL/2017 (A.Y. 2009-10) Smt. Anu Gera, Income Tax Officer, S-505, Greater Kailash-II, Vs. Ward : 22 (1) New Delhi – 110 048. New Delhi. PAN No. ADGPG7714G ( RESPONDENT ) ( APPELLANT ) Assessee by : Ms. Rano Jain, Advocate & Ms. Mansi Jain, C. A. Department by : Shri Kanv Bali, Sr. D. R. Date of Hearing 02.03.2023 Date of Pronouncement 05.04.2023 ORDER PER YOGESH KUMAR US, JM 1. This appeal is filed by the assessee against the order dated 27.…

M/S.KOTTAYAM CO-OPERATIVE AGRICULTURAL & RURAL DEVELOPMENT BANK LTD. vs. THE INCOME TAX OFFICER

ITA/34/2018HC Kerala15 Dec 2022

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

For Appellant: M/S.KOTTAYAM CO-OPERATIVE AGRICULTURAL & RURALFor Respondent: THE INCOME TAX OFFICER

…a reason to expand the meaning of a Taluk means as more than one or more Taluks. The explanation is clear and categorical. Applying the Golden Rule of interpretation, it is argued that the Explanation is clear and categorical as referring 1 [2009] 309 ITR 329 (Kar) 2 [2011] 331 ITR 211 (Karn) ITA Nos.34 & 35 of 2018 & 25 & 27 of 2019 15 to a Taluk. Explanation (b) of Section 80P(4) means that a society has its area of operation confined to a Taluk, and the principal object of the society is to provide for long-term credit for a…

THE MEENACHIL CO-OPERATIVE AGRICULTURAL AND RURAL DEVELOPMENT BANK LTD., vs. THE INCOME TAX OFFICER,

ITA/25/2019HC Kerala15 Dec 2022

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

For Appellant: M/S.KOTTAYAM CO-OPERATIVE AGRICULTURAL & RURALFor Respondent: THE INCOME TAX OFFICER

…a reason to expand the meaning of a Taluk means as more than one or more Taluks. The explanation is clear and categorical. Applying the Golden Rule of interpretation, it is argued that the Explanation is clear and categorical as referring 1 [2009] 309 ITR 329 (Kar) 2 [2011] 331 ITR 211 (Karn) ITA Nos.34 & 35 of 2018 & 25 & 27 of 2019 15 to a Taluk. Explanation (b) of Section 80P(4) means that a society has its area of operation confined to a Taluk, and the principal object of the society is to provide for long-term credit for a…

THE MEENACHIL CO-OPERATIVE AGRICULTURAL & RURAL DEVELOPMENT BANK LTD. vs. THE INCOME TAX OFFICER

ITA/35/2018HC Kerala15 Dec 2022

Bench: HONOURABLE MR.JUSTICE S.V.BHATTI,HONOURABLE MR.JUSTICE BASANT BALAJI

For Appellant: M/S.KOTTAYAM CO-OPERATIVE AGRICULTURAL & RURALFor Respondent: THE INCOME TAX OFFICER

…a reason to expand the meaning of a Taluk means as more than one or more Taluks. The explanation is clear and categorical. Applying the Golden Rule of interpretation, it is argued that the Explanation is clear and categorical as referring 1 [2009] 309 ITR 329 (Kar) 2 [2011] 331 ITR 211 (Karn) ITA Nos.34 & 35 of 2018 & 25 & 27 of 2019 15 to a Taluk. Explanation (b) of Section 80P(4) means that a society has its area of operation confined to a Taluk, and the principal object of the society is to provide for long-term credit for a…

KIRTHISIMHAN WIJEYANAYAKE,COIMBATORE vs. ACIT NON CORPORATE CIRCLE 2, COIMBATORE

The appeal stands partly allowed in terms of our above order

ITA 1854/CHNY/2018[2009-10]Status: DisposedITAT Chennai06 Dec 2022AY 2009-10

Bench: Hon’Ble Shri Mahavir Singh & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri R. Sivaraman (Advocate) – Ld. ARFor Respondent: Shri P. Sajit Kumar (JCIT) – Ld. DR
Section 143(3)Section 147Section 148Section 50DSection 54

…ion/address as in K.G. Rukminiamma's case or in Smt. V.R. Karpagam's case (supra). Punjab and Haryana High Court in Pawan Arya's case (supra) held that another judgement of Karnataka High Court which was cited before them being CIT v. D. Ananda Basappa [2009] 309 ITR 329/180 Taxman 4 is not applicable as in D. Ananda Basappa's case (supra) two flats were purchased in the same location and the two flats were merged into one by breaking the separating wall. On this basis, the Punjab and Haryana High Court held that D. Ananda Basappa's case (supra) did not apply to the case before it particularly on the ground that…

ITO WARD - 30(1), NEW DELHI vs. KUSUM GUPTA, NEW DELHI

In the result appeal filed by the Revenue Department, stands allowed for statistical purposes

ITA 914/DEL/2020[2015-16]Status: DisposedITAT Delhi28 Jul 2022AY 2015-16

Bench: Shri N.K. Billaiya & Shri N.K. Choudhryassessment Year: 2015-16

For Appellant: Shri Vijay Jindal, Ld. CAFor Respondent: ShriAnujGarg, Ld. Sr. DR
Section 250Section 54

…m the disallowance made by the assessee 8.11. However, it is pertinent to note that judgment of Gita Duggal (supra) has made it very clear in para 8 of the order and the 'a' does not mean singular Judgment of Karnataka [10] HC CIT vs D. AnandaBasappa (2009) 309 ITR 329 has been followed which reads as under: "8. It is the correctness of the above view that is questioned by the revenue and it is contended that the interpretation placed by the Tribunal gives rise to a substantial question of law. The assessee strongly relies upon the judgment of the Karnataka High Court (supra) which, it is stated, has become fi…

VENKATESHARAIYER SUBRAMANIAN,HOSUR vs. ACIT CIRCLE 1, HOSUR

The appeal stands partly allowed in terms of our above order

ITA 1594/CHNY/2019[2015-16]Status: DisposedITAT Chennai13 Jul 2022AY 2015-16

Bench: Hon’Ble Shri V. Durga Rao & Hon’Ble Shri Manoj Kumar Aggarwal, Am

For Appellant: Shri S. Sridhar (Advocate) – Ld. ARFor Respondent: Shri V. Justin (Addl.CIT) – Ld. DR
Section 143(3)Section 54Section 54F

…houses in India. 4. Interpreting the provisions of Section 54, Hon’ble Madras High Court in its decision titled as Tilokchand & Sons V/s ITO [105 Taxmann.Com 151 14/03/2019], applying the decisions of Hon’ble Karnataka High Court in CIT V/s D. Ananda Basappa [309 ITR 329] & CIT V/s Khoobchand M. Makhija [43 Taxmann.com 143 18/12/2013], held that if the word 'a' as employed under Section 54 prior to its amendment and substitution by the words 'one' with effect from 01/04/2015 could not include plural units of residential houses then there was no need to amend the said provisions by Finance Act No.2 of 2014 which t…

DESIRAZU SUNDARA SIVA RAO,BENGALURU vs. ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-6(3)(1), BENGALURU

In the result, appeals by the assessees are treated as partly allowed for statistical purposes and Stay Petition is dismissed

ITA 633/BANG/2021[2015-16]Status: DisposedITAT Bangalore24 Jun 2022AY 2015-16

Bench: Shri N. V. Vasudevan & Ms. S.Padmavathi

For Appellant: Shri. V. Srinivasan, AdvocateFor Respondent: Smt. Priyadarshini Baseganni, Addl. CIT(DR)(ITAT), Bengaluru
Section 54Section 54F

…54F is claimed. The same is in violation of proviso to sub-section of section 54F. This is in violation of section 54F of Income tax act. 8. Also, the judicial pronouncements cited by assessee in case of Commissioner of Income Tax V/s. D Ananda Basappa (2009) 309 ITR 329, Commissioner of Income Tax V/s Gumanmal Jain, (2017) 394 ITR 666 (Madras) have been perused. However, facts of the above cited cases are different from the present one. The judicial pronouncements of Honourable High Court of Karnataka and Honourable High court of Madras pertain to assessment years earlier to A.Y 2015-16 wherein rationale for ter…

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