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The High Court of Gujarat rejected the Revenue's application under section 256(2) of the Income-tax Act, 1961. The court held that the assessee, despite not having final deeds or registration of flats, was the legal owner and rightly taxed under sections 22 and 23. The Tribunal's decision was upheld based on the Supreme Court ruling in CIT v. Podar Cement Pvt. Ltd. (1997) 226 ITR 625. The court found no need to refer questions under section 256, and the applications were rejected with no costs.
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