COMMISSIONER OF INCOME TAX Vs. SAMPATHAMMAL CHORDIA

JUDGEMENT

(1.) THE questions referred to us at the instance of the Revenue .are as follows :

(2.) WHETHER, on the facts and in the circumstances of the case, the Appellate Tribunal was right in holding that the entire corporation tax of Rs. 66,770 should be deducted from the annual value though it is relatable to the earlier years for the purpose of computing the income from property?"

(3.) WE are therefore unable to accept the submission made by counsel for the Revenue that the actual rent can never be regarded as the amount which the landlord can reasonably be expected to receive from his property, for purposes of Section 23(1)(a) of the Act.