| Case ID |
093726af-bdee-4f2b-a55a-4184b52511ed |
| Body |
View case body. Login to View |
| Case Number |
D.B. IT REFERENCE NO. 29 OF 1974 |
| Decision Date |
Apr 20, 1984 |
| Hearing Date |
|
| Decision |
The Rajasthan High Court held that the annual value of a property should be determined under section 23(1) of the Income-tax Act, 1961, along with its first proviso. The court clarified that the second proviso to section 23(1) does not apply when calculating the annual value for the purpose of determining deductions for repairs under section 24(1). The court affirmed the Tribunal's decision, which stated that the annual value should be calculated without considering the second proviso, ensuring a clear basis for tax deductions related to property repairs. This ruling emphasizes the importance of correctly interpreting tax law provisions to ascertain taxable income accurately. |
| Summary |
In the case of Addl. Commissioner of Income Tax v. Instrumentation Ltd., the Rajasthan High Court addressed the interpretation of section 23(1) of the Income-tax Act, 1961. The case revolved around the annual value determination of residential units constructed by the assessee-company for its employees. The Income Tax Officer (ITO) initially calculated the annual value based on section 23(1) and allowed deductions under both the first and second provisos. However, upon appeal, the Tribunal ruled that only the first proviso should be considered for calculating the annual value, excluding the second proviso entirely. The court upheld this view, stating that the second proviso does not contribute to the computation of annual value for tax deductions. This case highlights the critical interpretation of tax laws, ensuring that deductions for repairs are calculated based on a clear and justifiable annual value, ultimately promoting compliance and clarity in tax assessments. Understanding the intricacies of tax law, particularly concerning annual values and deductions, can significantly impact tax liabilities for businesses and individuals. Tax professionals must stay informed about such rulings to provide accurate advice. Keywords such as 'Income-tax Act', 'annual value determination', and 'tax deductions for repairs' are essential for SEO optimization in legal discussions. |
| Court |
Rajasthan High Court
|
| Entities Involved |
|
| Judges |
N.M. Kasliwal,
S.N. Bhargava
|
| Lawyers |
R.N. Suroliya,
H.C. Rastogi
|
| Petitioners |
Addl. Commissioner of Income Tax
|
| Respondents |
Instrumentation Ltd.
|
| Citations |
1986 SLD 1750 = (1986) 160 ITR 689
|
| Other Citations |
Not available
|
| Laws Involved |
Income-tax Act, 1961
|
| Sections |
23(1),
24(1)
|