1986 (6) TMI 89

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..... re disposed of together in a common order. 2. The assessee had a small tiled house. It was demolished and a building consisting of two floors was constructed by the assessee. The building was left out to 6 persons for residential purposes. It was claimed before the ITO that each portion, occupied by a tenant for residential purposes, is a complete unit in itself and, therefore, is eligible for de .....

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..... residential purposes. In fact Sri M.J. Swamy ld. counsel for the assessee, contended that there are totally six residential units, three in the ground floor and three in the first floor. Each residential unit is having a hall, a dining room, Kitchen, with separate toilet and bath. They are let out to six different tenants enjoying self-sufficient residential accommodation. As a matter of fact, tw .....

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..... 1985) 156 ITR 369 (Mad) would be applicable to the instant case. 3. Having regard to rival submissions, we have no hesitation in upholding the contentions of the assessee. The case relied on by the departmental representative is in respect of a building consisting of several rooms used as a lodge. A residential accommodation, in our view, cannot partake of the nature of a lodge where people in tr .....

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