9911796707
TMI Blog1998 (11) TMI 80X X X X Extracts X X X X X X X X Extracts X X X X ..... l referred the following question for the consecutive assessment years 1986-87, 1987-88 and 1988-89 for the opinion of this court : "Whether, on the facts and in the circumstances of the case and coupled with the fact that for the assessment year 1983-84 the admitted annual letting value was Rs. 46,411, the Tribunal, on an interpretation of section 23 of the Income-tax Act is right in law and fa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... then observed that the rental value of the properties has been increasing year after year. He, therefore, took the annual letting value of the properties in question at Rs. 46,441 for each assessment year in question. The Deputy Commissioner of Income-tax (Appeals) estimated the annual letting value at Rs. 36,000 for each year under appeal. Aggrieved, both the assessee and the Revenue approache ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... al letting value at Rs. 46,441. No doubt, for the years under appeal the assessee declared the annual letting value in descending trend without giving any cogent reasons therefor. No reason has been shown by the assessee that in the next following years the annual letting value went on decreasing. Normally, as observed by the Assessing Officer, the annual letting value should gradually increase. S ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nt. Looking to the annual letting value declared for the assessment year 1983-84, the Assessing Officer took the view that there was no good reason to assess the annual letting value at a lesser figure for the next following years, as there was an increasing trend in the annual letting value and no decreasing trend was shown by the assessee. There being no supportive material that the annual letti ..... X X X X Extracts X X X X X X X X Extracts X X X X
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