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The Commissioner Of Income Tax vs Shri Sardarmal Kothari on 17 June, 2008

The assessee was required to get the house and occupancy certificate on or before 1-12-2011. But however, the assessee got the occupancy certificate of the property on 17-1-2014. The Tribunal further noted that the assessee submitted the documentary evidence to show that after purchasing the property, there was a civil suit filed by the other parties and the assessee could not complete the construction and the licence for constructing the house was accordingly delayed. The Tribunal further noted that Commissioner (Appeals) in his order relied upon the decision of the Madras High Court in the case of CIT v. Sardarmal Kothari [2008] 302 ITR 286 wherein, it is held that in order to get the benefit under section 54, the assessee need not complete the construction of the house and occupy the same. It is further noted that the assessee has invested the money and the occupancy certificate is delayed which is beyond the control of the assessee then the assessee is entitled for deduction under section 54 of the Act. The Tribunal as such found that the assessee was entitled for deduction under section 54 and consequently, dismissed the appeal of the revenue. Considering the said facts and the ratio of the judgment referred to herein above, it is to be found that there is no substantial question of law which arises for consideration in the present appeal under section 260A. Hence, no case is made out by the appellant for interference in the order passed by the Tribunal. The appeal stands accordingly rejected."
Madras High Court Cites 4 - Cited by 69 - Full Document
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