SUSHAM SINGLA Vs. COMMISSIONER OF INCOME TAX

JUDGEMENT

(1.) The present is a bunch of seven appeals, being I. T. A. Nos. 371 to 377 of 2015, pertaining to the assessment years 2001-02 to 2007-08, respectively, filed at the instance of the appellant-assessee to challenge therein the common order passed by the Income Tax Appellate Tribunal, Chandigarh Bench, Chandigarh (hereinafter referred to as - the Tribunal).

(2.) At the time of hearing of the appeals, Mr. Pankaj Jain, learned senior counsel appearing on behalf of the appellant-assessee sought to press only the following substantial question of law for our consideration, which, according to him, was common and arose to all the present appeals :- "Whether under the facts & circumstances of the case, pursuant to the explanation there is no charge-ability of rent which cannot be realized resultingly according to Sec. 23(1)(c) of the Act, the lessor of the amount expected to be let & as receivable shall be charged whereby not realizable is less resultingly no charge ?" The appeal is admitted on this question of law.

(3.) The appeal raises an interesting and an important question of law invoking the interpretation of Sections 22 and 23 of the Act. The wording of Sec. 23 does not admit of an easy answer.