DCIT, New Delhi vs. Sh. Niranjan Koirala, New Delhi
In the result, appeal of the Revenue is dismissed
ITA 2253/DEL/2010[2006-07]Status: DisposedITAT Delhi19 Aug 2025AY 2006-07
Bench: Shri Vikas Awasthy & Shri Avdhesh Kumar Mishraआअसं.2253/िद"ी/2010(िन.व. 2006-07) Deputy Commissioner Of Income Tax, Circle-31(1), R. No. 1405, 14Th Floor, E-2 Block, Pratyakshkar Bhawan, Civic Centre, Jln Marg, ...... अपीलाथ"/Appellant New Delhi बनाम Vs. Niranjan Koirala, 27, Akbar Road, New Delhi ..... "ितवादी/Respondent Pan: Aaupk-0483-B Assessee By : Shri Tarandeep Singh, Advocate Department By : Shri Manoj Kumar, Sr. Dr सुनवाई क" ितिथ/ Date Of Hearing : 23.05.2025 घोषणा क" ितिथ/ Date Of Pronouncement : : 19.08.2025 आदेश/Order Per Vikas Awasthy, Jm: This Appeal By The Revenue Is Directed Against The Order Of Commissioner Of Income Tax (Appeals)-Xxx, New Delhi (Hereinafter Referred To As 'The Cit(A)') Dated 18.02.2010, For Assessment Year 2006-07. 2. This Appeal Was Decided By The Tribunal Vide Order Dated 20.07.2018. Thereafter, The Revenue Filed Miscellaneous Application Seeking Rectification In The Order Of Tribunal On The Ground That The Additional Grounds Of Appeal Raised By The Revenue Vide Application Dated 13.08.2014 Remained To Be Decided. The Tribunal In Ma No. 732/Del/2018 Vide Order Dated 10.07.2023 Recalled The Order
For Appellant: Shri Tarandeep Singh, AdvocateFor Respondent: Shri Manoj Kumar, Sr. DR
Section 54F
…tena of judgements, one of which was pronounced in Smt. Tarulata Shyam Vs. CIT 108 ITR 345 (SC). It is also well settled that there is no room for purposive interpretation under the direct tax laws and in this connection one may advert to the ratios in (1998) 234 ITR 261 (MP) Laxmandas Pranchand Vs. Union of India & Ors.; (1999) 236 /TR 595 (Cal) CIT Vs. Central Concrete & Allied Products Ltd. and (2001) 252 ITR 1 (SC) CIT Vs. A.M. H. Ghaswala & Ors. 2.4 The legislative intent behind introduction of section 54F and subsequent amendments has always been to encourage purchase or construction of a new residential ho…