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2011 (6) TMI 890 - AT - Income TaxDeduction u/s 54F - Meaning of Residential House - CIT(A) deleted the addition which the AO had allowed in respect of only one unit by treating the units as two separate residential properties HELD THAT:- We find that issue is squarely covered in favour of the assessee by the decision of the Hon’ble Karnataka High Court in the case of COMMISSIONER OF INCOME-TAX VERSUS SMT. KG. RUKMINIAMMA [2010 (8) TMI 482 - KARNATAKA HIGH COURT], where it was held that, “The context in which the expression ‘a residential house’ is used in sec. 54 makes it clear that it was not the intention of the legislation to convey the meaning that it refers to a single residential house. As in the earlier part, the words used are buildings or lands which are plural in number and that is referred to as “a residential house”, the original asset. An asset newly acquired after the sale of the original asset also can be buildings or lands appurtenant thereto, which also should be “a residential house”. Therefore, the letter ‘a’ in the context it is used should not be construed as meaning “singular”. But, being an indefinite article, the said expression should be read in consonance with the other words ‘buildings’ and ‘lands’ and, therefore, the singular ‘a residential house’ also permits use of plural by virtue of sec. 13(2) of the General Clauses Act –COMMISSIONER OF INCOME-TAX AND ANOTHER VERSUS D. ANANDA BASAPPA [2008 (10) TMI 99 - KARNATAKA HIGH COURT]" We do not find any infirmity or illegality in the order of the CIT(A) and hence, uphold the same - Decision in favour of Assessee. Portfolio Management Fees - CIT(A) deleting the addition - HELD THAT:- ld. counsel of the assessee conceded that disallowance has been rightly made by the Assessing Officer. Hence, we allow this issue in favour of the Revenue.
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