How many judgments cite CIT v. K.G. Rukminiamma?

104 judgments on BharatTax cite CIT v. K.G. Rukminiamma (331 ITR 211), spanning 2013 to 2026.

Which sections of the Income Tax Act does CIT v. K.G. Rukminiamma come up under?

It is most often cited in judgments turning on Section 54F, Section 143(3), Section 147, Section 148, Section 143(1), Section 148A(b).

CIT v. K.G. Rukminiamma

331 ITR 211High Court2011#1050 most cited

What is CIT v. K.G. Rukminiamma authority for?

For capital gains exemption under Sections 54 and 54F of the Income Tax Act (prior to the 2015 amendment), the expression "a residential house" includes multiple residential units and should not be construed in the singular, by applying Section 13 of the General Clauses Act.

104

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2013 to 2026.

Also referred to as

CIT v. K.G. Rukminiamma · Section 54 · Section 54F · capital gains exemption · "a residential house" · multiple residential units · Section 13 General Clauses Act · singular plural interpretation · long term capital gain · residential house exemption

Sections most often in play

Section 54F Section 143(3)Section 147 Section 148 Section 143(1)Section 148A(b)Section 271(1)(c)Section 32

Issues it is cited on

section 54(1)section 13(2)indexed cost of acquisition section 54 section 54f date of transfer section 45 fair market value long term capital gain scrutiny assessment section 13 transfer

Judgments citing CIT v. K.G. Rukminiamma

ACIT 23(1), Mumbai vs. T.K. Venkateshwaran, Mumbai

In the result, appeal filed by the revenue is dismissed

ITA 8538/MUM/2011[2008-09]Status: DisposedITAT Mumbai21 Feb 2018AY 2008-09

Bench: Shri Saktijit Dey () & Shri G Manjunatha ()

Section 143(2)Section 54

…the residential units into a single habitable unit, then the residential units will qualify for exemption u/s 54 of the Income-tax Act, 1961. The assessee also relied upon the decision of Hon’ble Karnataka High Court in the case of CIT vs K.G. Rugmini Amma 331 ITR 211 (Karn) and CIT vs Anand D Basappa 309 ITR 329 (Karn). The CIT(A), after considering submissions of the assessee and also by following certain judicial precedents observed that the assessee is eligible for exemption u/s 54 in respect of re-investment of sale consideration for purchase of 3 residential apartments as all the 3 units have been con…

ITO, Ward-31(2), Kolkata vs. Smt. Namita Chowdhury, Kolkata

In the result the appeal by the revenue is dismissed

ITA 1595/KOL/2016[2009-10]Status: DisposedITAT Kolkata02 Feb 2018AY 2009-10

Bench: Hon’Ble Shri N.V.Vasudevan, Jm & Shri Waseem Ahmed, Am ] Assessment Year : 2009-10

For Appellant: Shri S.Dasgupta, Addl. CIT (DR)For Respondent: Shri Aloke Kumar Ghosh

Section 2Section 53ASection 54Section 55A

…four flats and one shop which she got as her share of the constructed area. The assessee made a claim for deduction u/s 54/54F of the Act and in this regard relied on the decision of the Hon’ble Karnataka High Court in the case of CIT vs Smt. K.G.Rukminiamma 331 ITR 211 (Kar) and the decision of the Hon’ble Madras High Court in the case of CIT vs Smt. V.R.Karpagam 373 ITR 121 (Mds). In the decision of the Hon’ble Karnataka High Court the assessee held a property which she gave it to a builder. The assessee got four flats representing 48% of the built up area and the remaining 52% was share of the builder. In res…

Ravi Shankar, Mumbai vs. Asst CIT 16(3), Mumbai

The appeal of the assessee is allowed

ITA 3270/MUM/2016[2012-13]Status: DisposedITAT Mumbai17 Jan 2018AY 2012-13

Bench: Shri Rajendra, Am & Shri Ravish Sood, Jm Mr. Ravi Shankar The Assistant Commissioner Flat No.S4, Apsara Building, बिधम/ Of Income Tax-16(3), Aaykar Nargis Dutt Road, Pali Hill, Bhavan, Mumbai 400 020 Vs. Bandra West, Mumbai-400 050 स्थामी रेखा सं./ जीआइआय सं./ Pan No. Adwpr7959N (अऩीराथी /Appellant) (प्रत्मथी / Respondent) :

For Appellant: Shri Madhur Agrawal, A.RFor Respondent: Shri Purushottam Kumar, D.R

Section 143(1)Section 143(2)Section 143(3)Section 54

…words importing the masculine gender shall be taken to include females; and (2) words in the singular shall include the plural, and vice versa. 14. This Court in the case of Commissioner of Income-Tax and Another -vs- Smt. K.G. Rukminiamma reported in (2011) 331 ITR 211 (Karn), had an occasion to consider Section 54 of the Act and had held as under: “For a proper appreciation of the aforesaid contention, it is necessary to have a careful look at Section 54 of the Income Tax Act, which reads as under: "54. Profit on sale of property used for residence - (1) Subject to the provisions of sub-section (2), where, in…

ACIT, Circle-4(1), Hyderabad vs. Fazlunnisa Begum, Hyderabad

ITA 66/HYD/2017[2012-13]Status: DisposedITAT Hyderabad09 Jan 2018AY 2012-13

Bench: Shri D. Manmohan & Shri S. Rifaur Rahman

For Appellant: Smt. Dr. Divya K.J - DRFor Respondent: Shri P. Vinod

Section 45Section 54Section 54F

…IN THE INCOME TAX APPELLATE TRIBUNAL HYDERABAD BENCHES “B” BENCH: HYDERABAD BEFORE SHRI D. MANMOHAN, VICE PRESIDENT AND SHRI S. RIFAUR RAHMAN, ACCOUNTANT MEMBER ITA. No.66/Hyd/2017 Assessment Year: 2012-2013 Asst. Commissioner of vs. Smt. Fazlunnisa Begum, Income Tax, Hyderabad. Circle-4(1), PAN: ABJPF 0159 M Hyderabad. (Appellant) (Respondent) For Assessee: Smt. Dr. Divya K.J - DR For Revenue : Shri P. Vinod Date of Hearing : 09.01.2018 Date of Pronouncement : 09.01.2018 ORDER PER D. MANMOHAN, VP. This appeal by the Revenue is directed against the order passed by Ld. CIT(A)-8, Hyderabad and it pertains to A.Y. 2…

Bhagwan Swaroop Agarwal, Jaipur vs. ITO, Jaipur

In the result, the appeal of the assessee is partly allowed

ITA 263/JPR/2014[2009-10]Status: DisposedITAT Jaipur31 Oct 2017AY 2009-10

For Appellant: Shri Rajeev Sogani (C.A.)For Respondent: Shri Punam Rai (D.CIT)

Section 24Section 48Section 54

…rstood to indicate a singular number. The Hon’ble High Court has allowed the claim u/s 54 in respect of two apartments purchased by the assessee in the said case. He has also relied upon the decision of Hon’ble Karnatka High Court CIT. vs. K.G. Rukminiamma 331 ITR 211 and submitted that the Hon’ble High Court has taken a consistent view on this issue that a residential house should not be taken as singular and more than one houses constitute a residential house for the purpose of section 54. 10. On the other hand, ld. DR has submitted that the assessee has purchased two houses in the name of wife and both a…

Mr. Arunkumar Nathan, Bangalore vs. Assistant Commissioner of Income Tax, Circle 2(3)(1), Bangalore

In the result, the appeal of the assessee is dismissed

ITA 1041/BANG/2017[2013 - 14]Status: DisposedITAT Bangalore25 Oct 2017

Bench: Shri Vijay Pal Rao & Shri Jason P Boaz

For Appellant: Shri S. Ramasubramanian, CAFor Respondent: Shri M.K. Biju, JCIT (DR) (ITAT)-3, Bengaluru

Section 54

…d claimed exemption under Section 54 of the Act which is not permissible. The assessee challenged the action of the Assessing Officer before the CIT (Appeals) and relied upon the decision of Hon'ble jurisdictional High Court in the case of CIT Vs. Rukmaniamma 331 ITR 211. The assessee also relied upon the decision of Hon'ble jurisdictional High Court in the case of DIT Vs. Khoobchand M Makhija 223 Taxman 189 as well as the decision in the case of CIT Vs. Sambandam Udaykumar 345 ITR 389. The CIT (Appeals) was not impressed with the contention of the assessee and also distinguished the decisions relied upon by the…

Sri. Shashank B. Gupta, Bangalore vs. Assistant Commissioner of Income-Tax, Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 2250/BANG/2016[2007-08]Status: DisposedITAT Bangalore28 Sept 2017AY 2007-08

Bench: Shri Vijay Pal Rao & Shri G. Manjunath

For Appellant: Shri Srinivasan, V AdvocateFor Respondent: Smt. Padma Meenakshi, JCIT (D.R)

Section 143(1)Section 148Section 54

…tion under Section 54 of the Act. The learned Authorised Representative of the assessee has relied upon the decision of the Hon'ble jurisdictional High Court in the case of Fathima Bai Vs. ITO 32 DTR 243 as well as in the case of CIT Vs. Smt. K.G. Rukminiamma 196 Taxmann 87. He has also relied upon the decision of Hon'ble jurisdictional High Court in the case of ACIT & Another Vs. Ananda Basappa 309 ITR 329 and submitted that when the assessee is receiving the built up area in the project then he is eligible for exemption under Section 54 of the Act. 9. On the other hand, the learned Departmental Representative h…

ITO, Ward-3(2), Bhubaneswar vs. Gaya Santara, Bhubaneswar

In the result, appeal filed by the revenue is dismissed and the appeal

ITA 468/CTK/2014[2008-09]Status: DisposedITAT Cuttack28 Jul 2017AY 2008-09

Bench: S/Shri N.S Saini & Pavan Kumar Gadaleassessment Year :2008-09

For Appellant: Shri S.K.Agarwalla, ARFor Respondent: Shri Subhendu Dutta, DR

Section 148Section 54Section 54F

…IN THE INCOME TAX APPELLATE TRIBUNAL, CUTTACK BENCH, CUTTACK BEFORE S/SHRI N.S SAINI, ACCOUNTANT MEMBER AND PAVAN KUMAR GADALE, JUDICIAL MEMBER Assessment Year :2008-09 Income Tax Officer, Ward- Vs. Gaya Santara, Plot No.63/A, 3(2), Bhubaneswar Sector-A, Zone-D, Mancheswar Industrial Estate, Bhubaneswar. PAN/GIR No.ADQPS 3243 J (Appellant) .. ( Respondent) Assessment Year :2008-09 Gaya Santara, Plot No.63/A, Vs. Income Tax Officer, Ward- Sector-A, Zone-D, 3(2), Bhubaneswar Mancheswar Industrial Estate, Bhubaneswar PAN/GIR No.ADQPS 3243 J (Appellant) .. ( Respondent) Assessee by : Shri S.K.Agarwalla, AR Revenu…

Shri.K.G.Shivarudraiah, Bangalore vs. Income-Tax Officer, Bangalore

In the result, the appeal of assessee is allowed for statistical purposes

ITA 2045/BANG/2016[2006-07]Status: DisposedITAT Bangalore26 May 2017AY 2006-07

Bench: Shri Sunil Kumar Yadav & Shri Jason P. Boazassessment Year : 2006-07

For Appellant: Shri Narendra Sharma, AdvocateFor Respondent: Shri M.K. Biju, Jt. CIT(DR)(ITAT)-3, Bengaluru

Section 143(3)Section 148Section 54F

…e compilation. In the case of Shri K.G. Adaveeshaiah in ITA No.2043/Bang/2016, the Tribunal has examined the aspect as to in which assessment year the capital gain accrued following the judgment of Hon'ble jurisdictional High Court in the case of T.K. Dayalu (331 ITR 211). The Tribunal has held that fair market value of the share of the assessee in the constructed area has to be considered as on the date of joint development agreement and for doing that exercise, the Tribunal has restored the matter to the AO. The Tribunal has also held that capital gain has to be accrued in the year in which the property was tra…

Smt.K.R.Lakshmi, Bangalore vs. Income Tax Officer, Bangalore

In the result, the appeal of the assessee is partly allowed

ITA 503/BANG/2017[2007-2008]Status: DisposedITAT Bangalore28 Apr 2017AY 2007-2008

Bench: Shri Arun Kumar Garodia & Shri Vijay Pal Rao

For Appellant: Shri Ashok Kulkarni, AdvocateFor Respondent: Shri AR.V.Sreenivasan, JCIT (D.R)

Section 4

…are to be taken into account. Therefore in view of the facts and circumstances of the case when the claim of the assessee on merit is prima facie allowable in view of the decision of Hon'ble jurisdictional High Court in the case of CIT Vs. K.G. Rukmani Amma 331 ITR 211, we set aside the impugned order of CIT (Appeals) on this issue and remit the same to the record of the CIT (Appeals) for deciding on merits. Needless to say that an opportunity of hearing be afforded to the assessee before passing the order. 10 10. In the result, the appeal of the assessee is partly allowed. Order pronounced in the open cour…

Ram Mohan Rai, New Delhi vs. ACIT, New Delhi

In the result ground No. 2 and 3 of the appeal of the assessee is allowed

ITA 6612/DEL/2016[2013-14]Status: DisposedITAT Delhi10 Apr 2017AY 2013-14

Bench: Shri H.S.Sidhu & Shri Prashant Maharishiram Mohan Rai, Vs. Acit, A-8/25, Vansant Vihar, Circle-33(1), New Delhi New Delhi Pan:Aaapr0728C (Appellant) (Respondent)

For Appellant: Sh. Ved Jain, AdvFor Respondent: Sh. FR Meena, Sr. DR

Section 143Section 234BSection 54

…'a residential house'. Whether 'a residential house' can include only one flat or more than one flat was the issue considered by Hon'ble Karnataka High Court in the case of CIT v. Smt. K.G. Rukminiamma(2010) 48 DTR (Kar) 377; (2011) 239 CTR (Kar) 435; (2011) 331 ITR 211 (Kar). Relying on Section 13 of the General Clauses Act, 1897, it was held as under by their Lordships at para 10 of the judgment: "(2) words in the singular shall include the plural, and vice versa" 10. The context in which the expression 'a residential house' is used in Section 54 makes it clear that, it was not the intention of the legislation…

Smt.Bayya Madhuram, Bangalore vs. Income Tax Officer, Bangalore

In the result, the appeal of the assessee is allowed

ITA 457/BANG/2017[2007-2008]Status: DisposedITAT Bangalore31 Mar 2017AY 2007-2008

Bench: Shri Vijay Pal Raoassessment Year : 2007-08

For Appellant: Shri G.S. Prashanth, CAFor Respondent: Shri AR.V. Sreenivasan, JCIT (DR)

Section 143(3)Section 54Section 54F

…in the form of these four flats then the assessee is eligible for deduction u/s. 54F for the entire sale consideration. In support of his contention, he has relied upon the decision of the Hon’ble jurisdictional High Court in case of CIT Vs K.G. Rukminiamma (331 ITR 211) as well as the decision of the Hon’ble Madras High Court in case of CIT Vs Gumanmal Jain (2017) (98 CCH 0093). Page 5 of 7 4. On the other hand the ld. DR has relied upon the orders of the authorities below and submitted that the language of section 54F is unambiguous regarding a residential house and therefore more than one residential house…

Chennakeshava Murthy, Bangalore vs. ITO, Bangalore

In the result, the appeals of the assessees are partly allowed

ITA 1234/BANG/2016[2006-07]Status: DisposedITAT Bangalore20 Jan 2017AY 2006-07

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Respondent: Smt. Swapna Das, JCIT

Section 133Section 133ASection 143(3)Section 148Section 54F

…ts and hence the assessee is entitled for deduction u/s 54/54F of the Act in respect of capital gain by considering the entire share in the residential project. Ld. AR of the assessee has relied upon the following decisions: 1. CIT Vs. Smt. K. G. Rukminiamma 331 ITR 211 (Karnataka) 2. CIT Vs. D. Ananda Basappa 309 ITR 329 (Karnataka) 3. Decision dated 20.7.2016 in case of Shri. N. G. Chandra reddy (HUF) Vs. DCIT ITA No. 390/Bang/2015 On the other hand, the learned DR has relied upon the orders of authorities below. 11. We have considered the rival submissions as well as relevant material on record. There is no…

C. Jagannath HUF, Bangalore vs. ITO, Bangalore

In the result, the appeals of the assessees are partly allowed

ITA 1231/BANG/2016[2006-07]Status: DisposedITAT Bangalore20 Jan 2017AY 2006-07

Bench: Shri Vijay Pal Rao & Shri Inturi Rama Rao

For Respondent: Smt. Swapna Das, JCIT

Section 133Section 133ASection 143(3)Section 148Section 54F

Pradipkumar P. Kanakia, Mumbai vs. DCIT Cir13(2), Mumbai

The appeal of the assessee is allowed

ITA 7688/MUM/2014[2011-12]Status: DisposedITAT Mumbai02 Dec 2016AY 2011-12

Bench: Shri Joginder Singh & Shri Rajesh Kumarassessment Year: 2011-12 Shri Pradipkumar Purshottam Dcit, Kanakia, Circle-13(2), बनाम/ C/O- Pratap Re-Rollers Pvt. Ltd Aayakar Bhavan, Vs. 18, Steel Yard House, Iron Mumbai-400020 Market, Sant Tukaram Road, Mumbai-400009 ("नधा"रती /Assessee) (राज"व /Revenue) Pan. No.Afvpk8451P

Section 54

…neither expressly nor by necessary implication prohibited. The ratio laid down by Hon'ble Delhi High Court in CIT vs Gita Duggal (2013) 357 ITR 153 (Del.), CIT vs D. Ananda Basappa (2009) 309 ITR 329 (Karn.)(para-3 & 6) and CIT vs Smt. K.G. Rukminiamma (2011) 331 ITR 211(Karn.)(Para 6 & 12 Pradipkumar Purushottam Kanakia 10) supports the case of the assessee. Hon'ble Delhi High Court in the case of CIT vs Gita Duggal (supra) affirmed the stand of the Tribunal taken in ITA NO.3613/Del./2010, order dated 07/06/2011. The vice versa is also applicable because exemption u/s 54 will be available in respect of any numb…

Asst CIT 19(3), Mumbai vs. Mushtaq I. Macchiwala, Mumbai

The appeal of the Revenue is dismissed

ITA 1563/MUM/2014[2008-09]Status: DisposedITAT Mumbai18 Nov 2016AY 2008-09

Bench: Shri Joginder Singh & Shri N.K. Pradhanassessment Year: 2008-09 Acit-19(3), Shri Mushtaq I.Macchiwala, Room No.305, 3Rd Floor, बनाम/ 101, Shree Prasad, Plot Piramal Chambers, Parel, No.517, 35Th Road, Tps-Ii, Vs. Mumbai-400012 Bandra (West), Mumbai-400050 (राज"व /Revenue) ("नधा"रती /Assessee) P.A. No. Aakpm5715C Shri Purushottam Kumar-Dr राज"व क" ओर से / Revenue By "नधा"रती क" ओर से / Assessee By Shri Prakash Pandit

Section 54

…neither expressly nor by necessary implication prohibited. The ratio laid down by Hon'ble Delhi High Court in CIT vs Gita Duggal (2013) 357 ITR 153 (Del.), CIT vs D. Ananda Basappa (2009) 309 ITR 329 (Karn.)(para-3 & 6) and CIT vs Smt. K.G. Rukminiamma (2011) 331 ITR 211(Karn.)(Para 6 & 10) supports the case of the assessee. Hon'ble Delhi High Court in the case of CIT vs Gita Duggal (supra) affirmed the stand of the Tribunal taken in ITA NO.3613/Del./2010, order dated 07/06/2011. Thus, the appeal of the Revenue is having no merit, consequently, we affirm the stand of the Ld. Commissioner of Income Tax (Appeal).…

Sh. Brij Bhushan Tayal, New Delhi vs. ACIT, New Delhi

In the result, the Appeal filed by the Assessee stands allowed

ITA 3272/DEL/2014[2009-10]Status: DisposedITAT Delhi13 Oct 2016AY 2009-10

Bench: Shri H.S. Sidhu

For Appellant: Sh. Ved Jain, Adv. & Sh. AshishFor Respondent: None

Section 142(1)Section 143(2)Section 143(3)Section 250Section 54

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH “SMC-2”, NEW DELHI BEFORE SHRI H.S. SIDHU, JUDICIAL MEMBER I.T.A. No. 3272/DEL/2014 (AY. 2009-10) BRIJ BHUSHAN TAYAL, ACIT, CIRCLE 19(1), A-1/2, WAZIRPUR INDUSTRIAL VS. NEW DELHI AREA, NEW DELHI – 110 034 (PAN:AADPT8072G) (APPELLANT) (RESPONDENT) Assessee by : Sh. Ved Jain, Adv. & Sh. Ashish Goel, CA Department by : None ORDER PER H.S. SIDHU, JM Assessee has filed the Appeal against the Order dated 28.3.2014 passed by the Ld. Commissioner of Income Tax (Appeals)—V, New Delhi pertaining to assessment year 2009-10 2. The grounds raised by the assessee read…

Mahesh Kumar Poddar, Mumbai vs. ITO WD 26(2)(2), Mumbai

ITA 1511/MUM/2016[2011-12]Status: DisposedITAT Mumbai24 Jun 2016AY 2011-12

Bench: Shri Joginder Singh() & Shri Ashwani Taneja (Acountant Member)

Section 54

…ted that the word “a” does not mean “one”. It was further submitted that this issue was covered in favour of the assessee on the basis of following judgements of various High Courts and different benches of the Tribunal: 1. CIT & Anr VS Smt. K.G. Rukminiamma 331 ITR 211 (Kar) 3 I.T.A. No.1511/Mum/2016 2. CIT vs Anand Basappa 309 ITR 329 (Kar) 3. CIT vs Khoochand M Makhija 223 Taxmann 189 (Kar) 4. CIT vs SAyed Ali Adil 352 ITR 418 (AP) 5. CIT vs Gita Duggal 357 ITR 153 (Del) 6. CIT vs V.R. Karpagam 373 ITR 127 (Mad) 7. Dy.CI vs Jai Trikanand Rao 149 ITD 112 (ITAT, Mum) 8. Girdhar Mohanani vs ITO ITA No.4591/Mum…

Vishal Dutt, Navi Mumbai vs. ITO WD 22(3)(4), Navi Mumbai

In the result, the appeal filed by the assessee in ITA N0

ITA 878/MUM/2014[2008-09]Status: DisposedITAT Mumbai16 Mar 2016AY 2008-09

Bench: Shri Sanjay Garg & Shri Ramit Kocharआयकर अपील सं./I.T.A. No. 878/Mum/2014 ("नधा"रण वष" / Assessment Year : 2008-09) Vishal Dutt, बनाम/ Income Tax Officer, Ward 205, B-Wing, Big Splash, – 22(3)(4), V. Sector – 17,Vashi, 3 Rd Floor, Tower No. 6, Navi Mumbai – 400703. Vashi Railway Station, Navi Mumbai – 400 703. "थायी लेखा सं./Pan : Aagpd 1553 M (अपीलाथ" /Appellant) .. (""यथ" / Respondent)

For Respondent: Shri Sanjeev Kashyap-(DR)

Section 14Section 143(2)Section 143(3)Section 54F

…आयकर अपील"य अ"धकरण “F” "यायपीठ मुंबई म"। IN THE INCOME TAX APPELLATE TRIBUNAL “F” BENCH, MUMBAI BEFORE SHRI SANJAY GARG, JUDICIAL MEMBER AND SHRI RAMIT KOCHAR, ACCOUNTANT MEMBER आयकर अपील सं./I.T.A. No. 878/Mum/2014 ("नधा"रण वष" / Assessment Year : 2008-09) Vishal Dutt, बनाम/ Income Tax Officer, Ward 205, B-Wing, Big Splash, – 22(3)(4), v. Sector – 17,Vashi, 3 rd Floor, Tower No. 6, Navi Mumbai – 400703. Vashi Railway Station, Navi Mumbai – 400 703. "थायी लेखा सं./PAN : AAGPD 1553 M (अपीलाथ" /Appellant) .. (""यथ" / Respondent) Assessee by Shri Neelesh Bajaj Revenue by : Shri Sanjeev Kashyap-(DR) सुनवाई क" तार"…

Satish Nikam, Navi Mumbai vs. ITO 19(3)(4), Mumbai

In the result, appeal stands allowed

ITA 1012/MUM/2013[2008-09]Status: DisposedITAT Mumbai04 Mar 2016AY 2008-09

Bench: Shri Saktijit Dey & Shri Ramit Kochar

For Appellant: Shri P.K. Parida a/wFor Respondent: Shri Manjunatha Swamy

Section 54

…iberal interpretation as section 54 is a beneficial provision. The Hon'ble Court held that the word “a” would not mean “one” residential house. He submitted, the same view was again reiterated by Hon'ble Karnataka High Court in CIT v/s K.G. Rukminiamma, [211] 331 ITR 211 (Kar.). He, therefore, submitted that the disallowance of exemption claimed by the assessee by interpreting the word “a” as “one” is not the correct interpretation of the statutory provision. Learned Counsel referring to instruction no.1081(F) no.207/20/76–IT(A)–II dated 3rd August 1977, submitted, as per the said instruction of the Board, assess…