CIT v. Ram Kishan Dass

413 ITR 337Reported decision#6673 most cited

What is CIT v. Ram Kishan Dass authority for?

An amending act can be purely clarificatory, intended to clarify a meaning already implicit in the principal Act. The word 'and' can be interpreted as 'or' in statutory interpretation if it leads to unintended results.

17

judgments rely on this decision, according to BharatTax’s citation analysis of 366,005 Indian tax judgments — from 2021 to 2024.

Also referred to as

CIT v. Ram Kishan Dass · 413 ITR 337 · clarificatory amendment · statutory interpretation · 'and' as 'or' · section 54(1) · section 142(2A)

Sections most often in play

Section 115JBSection 142(2A)Section 142(2C)Section 143(3)Section 153(1)Section 54Section 54F

Issues it is cited on

section 54(1)section 54esection 55asection 13(2)section 54eclong-term capital assetsection 53asection 53within four yearsfresh tangible materialsection 55circle rate

Judgments citing CIT v. Ram Kishan Dass

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

…in law that an Amending Act may be purely clarificatory in nature intended to clear a meaning of a provision of the principal Act, which was already implicit [See:Decision of the Supreme Court in CIT v. Ram Kishan Das [2019] 103 Taxmann.com 414/263 Taxman 657/413 ITR 337. In view of the aforesaid enunciation of law by different High Courts including this court and with a view to give definite meaning to the expression `a residential house', the provisions of section 54(1) were amended with an object to restrict the plurality to mean singularity by substituting the word `a residential house' with the word `one res…

DCIT, CC-05, New Delhi vs. Patanjali Ayurveda Limited, New Delhi

In the result, the appeal of the Revenue is dismissed and the Cross Objection of the assessee is allowed

ITA 2038/DEL/2021[2016-17]Status: DisposedITAT Delhi30 Jan 2024AY 2016-17

Bench: Dr. B. R. R. Kumarsh. Yogesh Kumar Us

For Appellant: Sh. S. S. Nagar, CAFor Respondent: Ms. Sapna Bhatia, CIT-DR
Section 142Section 143(3)

…IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCH ‘H’, NEW DELHI Before Dr. B. R. R. Kumar, Accountant Member Sh. Yogesh Kumar US, Judicial Member ITA No. 2038/Del/2021 : Asstt. Year: 2016-17 DCIT, Vs Patanjali Ayurved Ltd., Central Circle-05, D-26, Kapashera, Pushpanjali New Delhi-110055 Bijwasan, New Delhi-110061 (APPELLANT) (RESPONDENT) PAN No. AAECP4424C CO No. 75/Del/2023 : Asstt. Year: 2016-17 Patanjali Ayurved Ltd., Vs DCIT, D-26, Kapashera, Pushpanjali Central Circle-05, Bijwasan, New Delhi-110061 New Delhi-110055 (APPELLANT) (RESPONDENT) PAN No. AAECP4424C Assessee by : Sh. S. S. Nagar, CA Revenue by : M…

Dy CIT CC 1(4), Mumbai vs. M/S Ultratech Cement Ltd, Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 931/MUM/2020[2015-16]Status: DisposedITAT Mumbai12 May 2023AY 2015-16

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

Section 115Section 32Section 32ASection 80I

…s, drawing, plans are not installed by the assessee. 246 It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean “or”. The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: “Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and Page No. | 47 ITA NO. 465 & 931/MUM/2020 (A.Y: 2015-16) UltraTech Cement Limited sufficient reason". As a matter of statutory interpretation, it is well settled that…

Ultratech Cement Ltd, Mumbai vs. DCIT CC 1(4), Mumbai

In the result, appeal filed by the Revenue is dismissed

ITA 465/MUM/2020[2015-16]Status: DisposedITAT Mumbai12 May 2023AY 2015-16

Bench: Shri Aby T Varkey, Hon’Ble & Shri S. Rifaur Rahman, Hon'Blem/S. Ultratech Cement Limited V. Dcit, Central Circle-1(4) Ahura Centre, ‘B’ Wing 2Nd Floor Room No. 902, 9Th Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent) Dcit, Central Circle-1(4) V. M/S. Ultratech Cement Limited Room No. 902, 9Th Floor Ahura Centre, ‘B’ Wing 2Nd Floor Mahakali Caves Road Pratishtha Bhavan, Old Cgo Annexe Maharishi Karve Road Andheri (E), Mumbai- 400093 Mumbai- 400020 Pan: Aaacl6442L (Appellant) (Respondent)

Section 115Section 32Section 32ASection 80I

…s, drawing, plans are not installed by the assessee. 246 It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean “or”. The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: “Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and Page No. | 47 ITA NO. 465 & 931/MUM/2020 (A.Y: 2015-16) UltraTech Cement Limited sufficient reason". As a matter of statutory interpretation, it is well settled that…

Jt. CIT (OSD)- CC - 1(4), Mumbai vs. Ultratech Cement Ltd., Mumbai

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly allowed as indicated above

ITA 3764/MUM/2018[2014-15]Status: DisposedITAT Mumbai14 Dec 2021AY 2014-15

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Sushil Kumar Mishra
Section 115Section 153CSection 32Section 35Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL (VIRTUAL COURT) “J” BENCH, MUMBAI BEFORE SHRI C.N. PRASAD, HON'BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER ITA NOs.1412, 1413 2461 & 2462/MUM/2018 (A.Ys: 2012-13, 2011-12, 2013-14 & 2014-15) UltraTech Cement Ltd., v. DCIT, Central Circle -1(4) Ahura Centre, “B" Wing Pratishtha Bhavan, Old. C.G.O. Bldg., 2nd Floor, Mahakali Caves Road M.K. Road, Churchgate, Mumbai Andheri (E), Mumbai - 400093 PAN: AAACL6442L (Appellant) (Respondent) ITA NOs. 2871, 2872 &2873/MUM/2018 (A.Ys: 2011-12, 2012-13, 2013-14) DCIT, Central Circle -1(4) v. UltraTech Cement Lt…

DCIT- CC- 1(4), Mumbai vs. Ultratech Cement Ltd., Mumbai

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

ITA 2873/MUM/2018[2013-14]Status: DisposedITAT Mumbai14 Dec 2021AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Sushil Kumar Mishra
Section 115Section 153CSection 32Section 35Section 80I

…drawing, plans are not installed by the assessee. 246. It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean “or”. The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: “Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and sufficient reason". As a matter of statutory interpretation, it is well settled that the expression "and" can in a given context be read as "or" (see in this context I…

DCIT -CC-1(4), Mumbai vs. Ultratech Cement Ltd., Mumbai

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

ITA 2872/MUM/2018[2012-13]Status: DisposedITAT Mumbai14 Dec 2021AY 2012-13

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Sushil Kumar Mishra
Section 115Section 153CSection 32Section 35Section 80I

…drawing, plans are not installed by the assessee. 246. It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean “or”. The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: “Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and sufficient reason". As a matter of statutory interpretation, it is well settled that the expression "and" can in a given context be read as "or" (see in this context I…

DCIT - CC - 1(4), Mumbai vs. Ultratech Cement Ltd., Mumbai

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

ITA 2871/MUM/2018[2011-12]Status: DisposedITAT Mumbai14 Dec 2021AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Sushil Kumar Mishra
Section 115Section 153CSection 32Section 35Section 80I

…drawing, plans are not installed by the assessee. 246. It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean “or”. The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: “Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and sufficient reason". As a matter of statutory interpretation, it is well settled that the expression "and" can in a given context be read as "or" (see in this context I…

Ultratech Cement Ltd, Mumbai vs. DCIT Cen Cir 1(4), Mumbai

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

ITA 2462/MUM/2018[2014-15]Status: DisposedITAT Mumbai14 Dec 2021AY 2014-15

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Sushil Kumar Mishra
Section 115Section 153CSection 32Section 35Section 80I

…drawing, plans are not installed by the assessee. 246. It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean “or”. The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: “Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and sufficient reason". As a matter of statutory interpretation, it is well settled that the expression "and" can in a given context be read as "or" (see in this context I…

Ultratech Cement Ltd, Mumbai vs. DCIT Cen Cir 1(4), Mumbai

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

ITA 2461/MUM/2018[2013-14]Status: DisposedITAT Mumbai14 Dec 2021AY 2013-14

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Sushil Kumar Mishra
Section 115Section 153CSection 32Section 35Section 80I

…drawing, plans are not installed by the assessee. 246. It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean “or”. The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: “Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and sufficient reason". As a matter of statutory interpretation, it is well settled that the expression "and" can in a given context be read as "or" (see in this context I…

Ultratech Cement Ltd, Mumbai vs. DCIT Cen Cir 1(4), Mumbai

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly

ITA 1413/MUM/2018[2011-12]Status: DisposedITAT Mumbai14 Dec 2021AY 2011-12

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Sushil Kumar Mishra
Section 115Section 153CSection 32Section 35Section 80I

…drawing, plans are not installed by the assessee. 246. It is fairly well settled law that where the word "and" as is understood leads to unintended results, then it should be interpreted to mean “or”. The Supreme Court in the case of CIT vs. Ram Kishan Dass 413 ITR 337 (2019) SC has held: “Secondly, the alternate construction of the proviso is that the expression "and for any good and sufficient reason" should be read to mean "or for any good and sufficient reason". As a matter of statutory interpretation, it is well settled that the expression "and" can in a given context be read as "or" (see in this context I…

Ultratech Cement Ltd, Mumbai vs. DCIT Cen Cir 1(4), Mumbai

In the result appeals and Cross Objection of the assessee for Assessment Years 2011-12, 2012, 2013-14 and 2014-15 are partly allowed as indicated above

ITA 1412/MUM/2018[2012-13]Status: DisposedITAT Mumbai14 Dec 2021AY 2012-13

Bench: Shri C.N. Prasad, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

For Appellant: Shri Nishant ThakkarFor Respondent: Shri Sushil Kumar Mishra
Section 115Section 153CSection 32Section 35Section 80I

…IN THE INCOME TAX APPELLATE TRIBUNAL (VIRTUAL COURT) “J” BENCH, MUMBAI BEFORE SHRI C.N. PRASAD, HON'BLE JUDICIAL MEMBER AND SHRI S. RIFAUR RAHMAN, HON'BLE ACCOUNTANT MEMBER ITA NOs.1412, 1413 2461 & 2462/MUM/2018 (A.Ys: 2012-13, 2011-12, 2013-14 & 2014-15) UltraTech Cement Ltd., v. DCIT, Central Circle -1(4) Ahura Centre, “B" Wing Pratishtha Bhavan, Old. C.G.O. Bldg., 2nd Floor, Mahakali Caves Road M.K. Road, Churchgate, Mumbai Andheri (E), Mumbai - 400093 PAN: AAACL6442L (Appellant) (Respondent) ITA NOs. 2871, 2872 &2873/MUM/2018 (A.Ys: 2011-12, 2012-13, 2013-14) DCIT, Central Circle -1(4) v. UltraTech Cement Lt…

Dipti Nalin Parikh, Mumbai vs. ITO Ward - 17(1)(4), Mumbai

In the result, appeal of assessee is dismissed

ITA 3274/MUM/2019[2015-16]Status: DisposedITAT Mumbai09 Dec 2021AY 2015-16

Bench: Shri Laliet Kumar & Shri M Balaganeshdipti Nalin Parikh, Crescent Bay T4 Apt. 3103-3104, Near, Parel Bhoiwada, Opp. Cancer Society, Jeerabai Wadai Road, Parel (E), Mumbai-400012 Pan: Aabpp5053F ............ Appellant Vs. Ito-17(1)(4), 115, 1St Floor, Aayakar Bhavan, Mumbai-400020 ............ Respondent

For Appellant: Sh. Subramanian, ARFor Respondent: Sh. Sonia Kumar, Sr.DR
Section 54Section 54(1)

…law that an Amending Act may be purely clarificatory in nature intended to clear a meaning of a provision of the principal Act, which was already implicit. [See: Decision of The Supreme Court In CIT v. Ram Kishan Das [2019] 103 taxmann.com 414/263 Taxman 657/413 ITR 337. In view of aforesaid enunciation of law by different High Courts including this court and with a view to give definite meaning to the expression 'a residential house', the provisions of Section 54(1) were amended with an object to restrict the plurality to mean singularity by substituting the word 'a residential house' with the word 'one residen…

Smt. Kempanna Shylaja, Bangalore vs. Income Tax Officer, Ward - 6(3)(1), Bangalore

In the result, the appeal filed by the assessee is allowed

ITA 1105/BANG/2019[2013-14]Status: DisposedITAT Bangalore12 Jul 2021AY 2013-14

Bench: Shri Chandra Poojari, Am & Shri George George K, Jm

For Appellant: Shri L.Maheshkumar, AdvocateFor Respondent: Shri Priyadarshi Mishtra, Addl.CIT-DR
Section 54Section 54FSection 68

…in law that an Amending Act may be purely clarificatory in nature intended to clear a meaning of a provision of the principal Act, which was already implicit [See:Decision of the Supreme Court in CIT v. Ram Kishan Das [2019] 103 Taxmann.com 414/263 Taxman 657/413 ITR 337. In view of the aforesaid enunciation of law by different High Courts including this court and with a view to give definite meaning to the expression `a residential house’, the provisions of section 54(1) were amended with an object to restrict the plurality to mean singularity by substituting the word `a residential house’ with the word `one res…

Sh. Valmik Thapar, New Delhi vs. ACIT, New Delhi

Appeals are disposed of by this common order as indicated above

ITA 5767/DEL/2015[2007-08]Status: DisposedITAT Delhi11 Jun 2021AY 2007-08

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

…law that an Amending Act may be purely clarificatory in nature intended to clear a meaning of a provision of the principal Act, which was already implicit. [See: Decision of The Supreme Court In CIT v. Ram Kishan Das [2019] 103 taxmann.com 414/263 Taxman 657/413 ITR 337. In view of aforesaid enunciation of law by different High Courts including this court and with a view to give definite meaning to the expression 'a residential house', the provisions of Section 54(1) were amended with an object to restrict the plurality to mean singularity by substituting the word 'a residential house' with the word 'one residen…

ACIT, New Delhi vs. Sh. Valmik Thapar, New Delhi

Appeals are disposed of by this common order as indicated above

ITA 6726/DEL/2014[2010-11]Status: DisposedITAT Delhi11 Jun 2021AY 2010-11

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

…law that an Amending Act may be purely clarificatory in nature intended to clear a meaning of a provision of the principal Act, which was already implicit. [See: Decision of The Supreme Court In CIT v. Ram Kishan Das [2019] 103 taxmann.com 414/263 Taxman 657/413 ITR 337. In view of aforesaid enunciation of law by different High Courts including this court and with a view to give definite meaning to the expression 'a residential house', the provisions of Section 54(1) were amended with an object to restrict the plurality to mean singularity by substituting the word 'a residential house' with the word 'one residen…

Shri Valmik Thapar, New Delhi vs. DCIT, New Delhi

Appeals are disposed of by this common order as indicated above

ITA 6346/DEL/2014[2010-11]Status: DisposedITAT Delhi11 Jun 2021AY 2010-11

Bench: Hon’Ble Justice P.P. Bhatt & Shri Prashant Maharishi(Through Video Conferencing) Shri Valmik Thapar, Vs. Acit, 19, Kautilya Marg, Circle-53(1), New Delhi New Delhi (Appellant) (Respondent) Shri Valmik Thapar, Vs. Dcit, M/S. R. N. Khanna & Company, Ca, Circle-32(1), 14-15F, Shivam House, Connaught New Delhi Place, New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Acit, Vs. Shri Valmik Thapar, Circle-53(1), 19, Kautilya Marg, New Delhi New Delhi Pan: Aacpt7098K (Appellant) (Respondent) Assessee By : Shri Salil Agarwal, Senior Advocate Along With Shri Shailesh Gupta, Shri Mahur Agarwal, Advocates Revenue By: Shri H. K. Choudhary, Cit Dr Date Of Hearing 11/06/2021 (Last Hearing) Date Of Pronouncement 11/06/2021. O R D E R Per Prashant Maharishi, A. M. 1. These Are Three Appeals For Two Assessment Years Pertaining To One Assessee, Mr. Valmik Thapar, A Resident, Individual [Assessee]. Assessee Filed Ita Number

For Appellant: Shri Salil AgarwalFor Respondent: Shri H. K. Choudhary, CIT DR
Section 143Section 147Section 54Section 54E

…law that an Amending Act may be purely clarificatory in nature intended to clear a meaning of a provision of the principal Act, which was already implicit. [See: Decision of The Supreme Court In CIT v. Ram Kishan Das [2019] 103 taxmann.com 414/263 Taxman 657/413 ITR 337. In view of aforesaid enunciation of law by different High Courts including this court and with a view to give definite meaning to the expression 'a residential house', the provisions of Section 54(1) were amended with an object to restrict the plurality to mean singularity by substituting the word 'a residential house' with the word 'one residen…

CIT v. Ram Kishan Dass (413 ITR 337) — Cited in 17 Judgments | BharatTax