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Yogesh Sunderlal Shah,F/107, Shreepal Industrial Estate, New Oshivara Bridge,S.V. Road, Jogeshwari (W),Mumbai 400 102. Vs. The Assistant Commissioner of Income Tax 24(1), C/13, Pratyakshakar Bhavan, BKC, Bandra (East), Mumbai 40 051.
September, 24th 2012
            IN THE INCOME TAX APPELLATE TRIBUNAL
                    MUMBAI "G" BENCH, MUMBAI

     BEFORE SHRI D.K. AGARWAL, JUDICIAL MEMBER AND
       SHRI RAJENDRA SINGH, ACCOUNTANT MEMBER

                      ITA No.1876/M/2012
                   Assessment Year: 2008-2009

Yogesh Sunderlal Shah,                      The Assistant Commissioner of
F/107, Shreepal Industrial                  Income Tax 24(1), C/13,
Estate, New Oshivara Bridge,                Pratyakshakar Bhavan, BKC,
S.V. Road, Jogeshwari (W),            Vs.   Bandra (East),
Mumbai ­ 400 102.                           Mumbai ­ 40 051.
PAN: AAKPS 2779 L
           (Appellant)                               (Respondent)


                          Appellant by : Shri K. Gopal

                     Respondent by : Shri Jitendra Singh &
                                     Shri Satendra Pande


                      Date of hearing: 7.8.20012
                      Date of order : 21.9.2012

                                ORDER

PER RAJENDRA SINGH, A.M.


1.    This appeal by the assessee is directed against the order dated

27.2.2012 of CIT (A) for the assessment year 2008-2009.        The only

dispute raised in this appeal is regarding allowability of exemption u/s

54 of the Act in respect of capital gain earned by the assessee from

sale of house property.
                                    2                  ITA No.1876/M/2012
                                                       AY : 08-09





2.    The facts in brief are that during the assessment proceedings it

was noted by the AO that the assessee had sold a Bungalow No.32 at

Dariyalal C.H. Society, Mumbai 49, for a consideration of Rs. 3.50

crores on 8.8.2007.   On 16.8.2007, the assessee purchased tenancy

rights in two flats in the third floor of `Symphony' situated at junction

of 8th and 12th Road, Khar (West), Mumbai, for a consideration of Rs.

1.85 crores. The assessee computed the long term capital gain from

sale of residential Bungalow at Rs.2,13,02,427/- which was claimed

exempt to the extent of Rs.2,04,11,610/- because of the investments

made in acquisition of the tenancy rights in the new two flats. The AO,

however, observed that the exemption u/s 54 in respect of capital gain

from sale of residential house property was available only when the

assessee purchased or constructed a new residential flat.               The

assessee purchased only tenancy rights. The AO, therefore, asked the

assessee to explain as to why the claim u/s 54 should not be rejected.

The assessee submitted that he had acquired tenancy rights in

perpetuity in the new flat which had to be considered as transfer of

ownership of the flat.   It was pointed out that as per the tenancy

agreement, the assessee was required to use the said flat for

residential purposes only and not for other purposes and the assessee

was also entitled to bequeath rights in respect of the said flat to any

other person subject to beneficiary complying with the terms of
                                    3                  ITA No.1876/M/2012
                                                       AY : 08-09


agreement.    The assessee was also entitled to sublet or to give on

leave and license the said flat and the landlord was not required to

levy and charge transfer fees in respect of such assignment.            The

assessee could also avail or raise loan against the flat. Therefore, it

was submitted that the assessee was as good as owner of the flat

which had been acquired for use as a residential house and, therefore,

the assessee was entitled to exemption u/s 54 of the Income Tax Act.


2.1   The AO, however, did not accept the contentions raised. It was

observed by him that there could not be any dispute that the assessee

had purchased only the tenancy rights on paying the monthly rent of

Rs. 500/- p.m. to the landlord. The assessee had neither purchased

the flat nor constructed the flat as required u/s 54. He also referred to

clause-12 of the agreement as per which the tenant was not required

to make any structural alteration in the flat let out. Further, clause-17

provided that the right of the tenant was limited and restricted to the

said flat and nothing more.    The said clause also provided that the

landlord was entitled to carryout further construction on the said plot

and / or building without any recourse to tenant and in case any

specific permission / no objection certificate was required, the tenant

was required to grant his irrevocable consent / no objection. AO also

observed that all the rights of the assessee regarding raising loan,

transferring the flat were subject to the permissions or conditions laid
                                    4                   ITA No.1876/M/2012
                                                        AY : 08-09





down by the society.       Further, the owner of the flats was the

Laxminagar    Co-operative   Housing    Society   and   the    subsequent

purchasers were tenants.     The AO also observed that no doubt the

tenancy right was a capital asset but this was not the type of the asset

for which exemption u/s 54 was available.          The exemption was

available only in case of purchase or construction of the flat. The AO

referred to the judgment of the Hon'ble Supreme Court in the case of

CIT vs. TN Aravinda Reddy (120 ITR 46) (SC) in which it was held that

the word "purchase" occurring in section 54(1) had to be given its

common meaning i.e. buy for a price or equivalent of price by

payment in kind or adjustment towards a debt or for other monetary

consideration. The person who is the owner of the property should

possess absolute right in the property which was not so in this case.

The AO, therefore, rejected the claim of the assessee of exemption u/s

54 of the Act in respect of tenancy rights acquired in the new flat.

Accordingly, the claim of deduction u/s 54 of Rs. 2,04,11,610/- was

disallowed.



3.    The assessee disputed the decision of AO and submitted before

the CIT (A) that all the conditions for purchase of a flat were satisfied

as the assessee had taken possession of the flat and full payment of

purchase consideration of Rs.1.85 crores had been made in addition to
                                    5                  ITA No.1876/M/2012
                                                       AY : 08-09


monthly rent of Rs. 500/-. The assessee had also paid stamp duty @

5% of the consideration of Rs. 1.85 crores amounting to Rs. 9.25

lakhs. Thus, the residential house had been conveyed to the assessee

within the meaning of the word "conveyance" as defined in clause-9 of

section 2 of Bombay Stamp Act, 1958. The assessee had the right to

mortgage the said flat or re-sale the said flat and all future benefits on

the said flat were allowed to the assessee.      The assessee was also

authorised to bequeath the rights with respect to the said flat. It was

also pointed out that under the provisions of Section 27 (iii)(b), the

acquisition of tenancy rights in perpetuity amounted to ownership of

the property for the purposes of computation of income from house

property.   Similar provisions were contained in section 269UA(f).

Since, the assessee had been given the possession of the property, it

would constitute transfer u/s 2(47) for the purpose of capital gain. It

was further pointed out that legal title in respect of the flat was not

necessary for the purpose of claiming exemption u/s 54 of the Act.

The assessee placed reliance on the judgment of Hon'ble Supreme

Court in case of CIT vs. Podar Cement Ltd. (226 ITR 625) (SC),

judgment of Hon'ble Supreme Court in case of R.B. Jodha Mal Kuthiala

vs. CIT (82 ITR 570) and the judgment of Hon'ble Bombay High Court

in case of CIT vs. D.V. Laxmichang Nagpal Nagda (211 ITR 804). It

had been held in the said judgments that owner is the person who can
                                    6                  ITA No.1876/M/2012
                                                       AY : 08-09


exercise the right of owner in his own right and legal title of the

property was not necessary. The CIT (A), however, was not satisfied

with the explanation given.       It was observed by him that the

judgments relied upon were distinguishable and were not applicable to

the present case.   The CIT (A) referred to the judgment of Hon'ble

Bombay High Court in case of Hameed Jaffery vs. CIT reported in 227

ITR 724 (Bom) in which it was held that as per the provisions

contained u/s 54 at the relevant time, the assessee was required to be

in occupation of the property for his own residence or residence of his

parents as a owner in the two year period preceding to the date of

transfer. Since, the assessee was not owner of the property for the

full two year period, the claim of exemption u/s 54 was denied. The

same view was followed in CIT vs. Gopaldas H. Hansrajani (239 ITR

523).   By applying the same principle, the CIT (A) observed that

purchase of property by the assessee should be as a owner and not as

a tenant. The assessee in this case was not a owner of the property

and was only a tenant on a monthly rent of Rs. 500/- and therefore,

the provisions of section 54 were not applicable for exemption of

capital gain on sale of the residential house as the capital gain had not

been invested in purchase or construction of a new residential house.

The provisions of section 54 were plain and unambiguous and,

therefore, the same could not be applied in case of purchase of
                                     7                 ITA No.1876/M/2012
                                                       AY : 08-09


tenancy right in respect of flat.    CIT (A) accordingly confirmed the

disallowance of claim of deduction u/s 54 of the Act aggrieved by

which the assessee is in appeal before the Tribunal.



4.    Before us, the learned AR for the assessee submitted that

Laxminagar Cooperative Housing Society was the owner of the

property. Since, the rules of the society did not permit conveyance of

the land, only the tenancy rights were given. The property had been

constructed by Kasmita Properties Pvt. Ltd., to whom the landlord i.e.

A.D. Daru and S.D. Daru had given development rights. The assessee

had acquired the tenancy right on payment of non-refundable deposit

of Rs. 1.85 crores in addition to monthly rent of Rs. 500/-.            The

learned AR for the assessee reiterated the submissions made before

the lower authorities that as per clause-12 of the agreement, the

tenant had unfettered rights to assign, transfer or sublet his flat. The

assessee was also entitled to make alternation in the interior of flat in

terms of clause-12 of the agreement.       It was pointed out that the

assessee had perpetual tenancy right which had been deemed as a

owner under the provisions of section 27(iii)(b) and also for the

purposes of section 269UA(f).       Thus, the income from the flat was

assessable as the income from house property. Further, the assessee

had been handed over the possession of the flat which amounted to
                                   8                  ITA No.1876/M/2012
                                                      AY : 08-09


transfer under the provisions of section 2(47). The assessee had also

paid stamp duty @ 5% which also shows that it had been treated as a

case of transfer of flat. The learned AR argued that the purposes of

section 54 was to acquire a new residential house and mode of

acquisition was not very relevant. The assessee had, therefore, to be

treated as legal owner for all purposes. Reference in this regard was

made to the CBDT Circular No.8/2/169/15(A-1). He also referred to

the legal opinion of Maya Bhatt & Co., a copy of which was placed at

page 61 of the paper book. The learned AR also placed reliance on the

decision of Mumbai Bench of the Tribunal in the case of M/s Prema P

Shah vs. ITO (100 ITD 60) in support of his contentions.



4.1. The learned DR, on the other hand, strongly supported the

orders of the authorities below. It was argued that the words u/s 54

were `purchase or construction of a new house' and not acquisition

and, therefore, the section could apply only in case of the purchase of

a new flat or construction of a new flat and not to acquisition by any

other mode.    It was also submitted that the provisions of section

27(iii)(b) relied upon by the learned AR, treating the perpetual tenancy

as ownership, was limited to the application of the section 22 of the

Act regarding assessment of income from house property. Similarly,

the provisions of section 269UA(f) were applicable for the purposes of
                                   9                  ITA No.1876/M/2012
                                                      AY : 08-09


presumptive purchase of the properties.      These provisions had no

application to section 54 of the Act. The learned DR also argued that

the provisions of section 54 were exemption provisions and in respect

of such provisions, in case there are two interpretations, the one which

is favourable to the Revenue has to be followed as held by the Hon'ble

Supreme Court in case of Novopan India Ltd. (3 SCR 549). He placed

reliance on the judgment of Hon'ble Bombay High Court in case of

Hameed Jaffery vs. CIT (227 ITR 724) which was later followed in 239

ITR 523 (Mum).      He also placed reliance on judgment of Hon'ble

Supreme Court in case of Suraj Lamp and Industries Pvt. Ltd. (340 ITR

1) in which it was held that the registered deed of conveyance is the

only mode of legal transfer and that general power of attorney, etc do

not create title or interest in the property. The learned DR referred to

the various provisions of the tenancy agreement to point out that the

rights of the tenant in the flat were limited. He referred to clause-15

of the agreement which provided that the landlord was permitted to let

out the flat only on tenancy basis and in    no other manner.        Thus,

agreement itself provided that it was a case of tenancy and not

purchase.   It was also submitted that though as per clause-10, the

tenant was entitled to take loan, that was only against right of the

tenant in the flat and not against any ownership right. The clause-17

provided that the right of tenancy was limited and restricted to the
                                   10                   ITA No.1876/M/2012
                                                        AY : 08-09


said flat and no more.   Further, clause- 19 provided that the tenant

was not entitled to do any act that affected the right of the landlord in

the said building and in the said property. It was pointed that in the

agreement the words "tenant" and "landlord" had been used and not

"purchaser or seller" of the flat. Learned DR also referred to clause-12

of the agreement which clearly provided that the tenant was not

entitled to make any structural changes in the said flat.           He was

entitled to make   changes only inside the flat with MCD permission

without affecting the outer walls. The learned DR further pointed out

that though clause-21 gave unfettered right to the tenant to assign,

transfer or sublet the flat but such unfettered right was only in respect

of tenancy right and not as owner of the flat.       It was accordingly

argued that the assessee was only a tenant in the new flat and not

owner of the flat and, therefore, it could not be said that the assessee

had purchased or constructed a new flat.      Accordingly, the claim of

exemption under section 54 was not allowable and it was therefore

urged that the order of the CIT (A) should be upheld.


5. We have perused the records and considered the rival contentions

carefully. The dispute is regarding allowability of exemption under

section 54 of the I.T. Act in respect of capital gain earned by the

assessee from sale of a residential property. Under the provisions of

section 54, capital gain arising from transfer of a residential house
                                  11                 ITA No.1876/M/2012
                                                     AY : 08-09


income from which is chargeable under the head income from house

property is exempt if the capital gain is invested in purchase of a new

residential house within one year before or two years after date on

which transfer took place or assessee has constructed a new

residential house within the period of three years after the date of

transfer. In the present case, assessee had sold the residential

property for Rs.3.50 crores on 8.8.2007 and thereafter on 16.8.2007

assessee purchased tenancy rights in flats in the building "Symphony"

on deposit of Rs.1.85 crores which was not refundable and on payment

of monthly rent of Rs.500/-. The case of the assessee is that tenancy

right was perpetual and assessee was therefore deemed owner of the

property under section 27(iiib). The flat taken for tenancy was to be

used for residential purposes and income from the same was

chargeable under income from house property. It has also been

submitted that under the provisions of tenancy agreement, the

assessee was entitled to subletting the flat or to give on leave and

license and could also avail loan against said tenancy right. The

assessee had also the right to assign or transfer the right in the flat

and further entitled to make alteration in the flat. Therefore, it has

been argued that for all practical purposes, the assessee was owner of

new residential property and therefore, assessee should be entitled for

exemption under section 54 of the Act. The case of the revenue is that
                                  12                 ITA No.1876/M/2012
                                                     AY : 08-09


as per requirement of section 54, the assessee had to purchase or

construct a new residential house and then only is entitled for

exemption under the said section. Acquisition of new residential house

by any other mode is not prescribed and, therefore, assessee is not

entitled for exemption.


5.1   We have carefully considered the various aspects of the matter.

We find that under the provisions of section 54, exemption of capital

gain is available in respect of transfer of residential house owned by

the assessee. The purpose of the section is to grant exemption in case

the assessee acquires a new residential house by investing the capital

gain as an owner. It is because of this reason, the words used in

section 54 are "purchase" or "construction" of a new residential house.

The requirement of section is not that assessee may acquire a new

residential house by any other mode. The word "purchase" appearing

in section 54   had come for consideration before Hon'ble Supreme

Court in case of CIT vs. T.N. Arvinda Reddy (120 ITR 46) in which

Hon'ble Supreme Court held that the word "purchase" appearing in

section 54(1) has to be given its common meaning i.e. buy for a price

or equivalent of price by payment in kind or adjustment towards a

debt or for other monetary consideration. Thus, for application of

provisions of section 54, the assessee has to buy a property as an

owner. In this context, it may be appropriate to refer to the judgment
                                   13                 ITA No.1876/M/2012
                                                      AY : 08-09


of Hon'ble High Court of Bombay in case of Hameed Jaffery vs. CIT

(227 ITR 724) which was in the context of old provision of section 54

which required that the property which had been transferred should be

in the occupation of the assessee for his own residence or for the

residence of his parents. The Hon'ble High Court held that occupation

should be as an owner and not as tenant.         The exemption under

section 54 from capital gain is available to an assessee, who invests

the capital gain in similar asset being a residential house which would

obviously mean that acquisition of the house should be as an owner as

the capital gain covered under section 54 is the capital gain arising

from transfer of a residential house owned by the assessee.


5.2   Further, as rightly pointed out by the ld. CIT-DR, provisions of

section 54 are exemption provisions and, therefore, in case two

interpretations are possible i.e. whether assessee should acquire the

new residential house as owner or even the perpetual tenancy right

would suffice, the interpretation favorable to the revenue shall be

followed as held by Hon'ble Supreme Court in case of Novopan India

Ltd. (3 SCR 549). In the said case, the Hon'ble Supreme Court held

that the principle that in case of ambiguity, a taxing statute should be

construed in favour     of the   assessee would not apply to               the

construction of an exception or an exempting provision; these have to

be construed strictly. The Hon'ble Supreme Court also held that the
                                    14                 ITA No.1876/M/2012
                                                       AY : 08-09


person invoking an exception or an exemption provision to relieve him

of the tax liability must establish clearly that he is covered by the said

provision. In case of doubt or ambiguity, benefit of it must go to the

State. Following the said judgment, therefore, even if there is some

ambiguity in the provision, the same has to be interpreted in favour of

the revenue because it is an exemption provision. In the present case,

there is no ambiguity. The provision refers to purchase or construction

of a new residential house and it is quite obvious that the same should

be as an owner and not as perpetual tenant.


5.3   The ld. AR for the assessee has referred to the provisions of

section 27(iiib) r.w.s. 269 UA(f) as per which a person having lease

hold right for more than 12 years in property including the period

renewal of lease if any has to be considered as deemed owner. Since

the assessee in this case had perpetual lease, it has been argued that

the assessee was deemed owner and therefore, should be entitled to

exemption under section 54 of the Act. However, we find that the

provision of deemed owner under section 27(iiib) is only for the

purposes of section 22 to 26 as clearly mentioned in the said section,

which relate to computation of income from house property. Therefore,

argument of deemed owner is relevant only in connection with

computation of income from house property and not in relation to

exemption provisions of section 54. Similarly, treating the tenancy as
                                   15                 ITA No.1876/M/2012
                                                      AY : 08-09


conveyance under the Bombay Stamp Act was only for the purpose of

payment of stamp duty and cannot be considered as conveyance of

the title of the property to the assessee as an owner. As for taking

possession of the flat, taking possession can not be considered as

ownership as the possession had been taken as a tenant and not as an

owner of the flat.



5.4   It has also been argued that under the provisions of tenancy

agreement, assessee had right to bequeath the flat, sub-let/lease it

and was also entitled to raise loan against the flat. The assessee had

also right to make alteration in the flat and therefore, considering

these factors and also the fact that the lease was perpetual, the

assessee had to be considered as owner of the flat, entitled to

exemption under section 54. The arguments are however not

convincing. No doubt, the assessee was permitted to sub-let the flat,

to bequeath it and to raise loan but such powers were only in relation

to tenancy right of the assessee and not as owner of the flat. All these

facilities to which assessee was entitled was only against right of the

assessee   as tenant in the flat and not as owner. Further, clause-12

clearly provides that the tenant was not entitled to make any

structural changes in the flat which clearly shows that the assessee

was not the owner because an owner has full right in relation to his
                                    16                 ITA No.1876/M/2012
                                                       AY : 08-09


property. The said clause also provided that the tenant had no right to

put up any construction on the aforesaid plot of land. The clause-17

provided that right of tenant was limited and restricted to the said flat.

Further clause-19 placed restriction that tenant was not entitled to do

any act that affected the right of the land lord in the said building and

in the said property which clearly shows that the assessee did not

have the status of land lord and was only a tenant. The owner of the

flat was Laxminagar Co-operative housing Society and as per rules of

the society, there was no provision of transfer of land and, therefore,

subsequent buyers were only tenants and not owners.


5.5   The ld. AR for the assessee has placed reliance on Circular

No.8/2/169-IT(A)-1 dated 25.3.1969 to argue that in terms of the said

Circular the assessee was owner for all practical purposes. The said

circular in our view is distinguishable as the same related to a situation

in which the builder had transferred land and building to the society

and society had allotted the tenancy to the purchasers and possession

of the flat had been given. Thus, in that case society had ownership of

land as the land had been transferred to the society and it was under

these circumstances that it was held that for all purposes including

adjustment and recovery, individual members could be regarded as

legal owners. In the present case there was restriction on transfer of

land which was owned by Laxminagar Co-operative Society. The
                                    17                 ITA No.1876/M/2012
                                                       AY : 08-09


subsequent buyers were only tenants and not owners of land and this

was the reason that only tenancy rights were given to various persons

including the assessee. The builder had no right in the land and,

therefore, only, tenancy right could be given to the buyers. Moreover

the circular related to a case where individual members had paid the

entire cost of the flat as purchaser, which is not so in the present case.

Therefore, the circular does not find any application to the facts of the

case. The ld. AR has also referred to opinion of the solicitor, Maya

Bhatt & Co. placed at page 61 of the paper book but there is nothing in

the opinion to show that the assessee was an owner. The solicitor had

only stated that the land lord had given irrevocable right to the builder

Kashmita Property Pvt. Ltd. to enter the property for the purpose of

development and that the property was free from any encumbrance.

Thus the solicitor had given only an opinion that the builder was

entitled to development right in the property for construction of the

building. So the opinion given is of no help to the assessee. The ld. AR

has also placed reliance on the decision of the Tribunal in the case of

Prema P. Shah vs. ITO (100 ITD 60) and based on the said decision it

has been argued that the assessee has to be treated as owner.

However, on careful perusal of the said decision we find that the said

decision is distinguishable. The property in the said case was on

perpetual lease of 150 years. The Tribunal noted that the rent fixed
                                    18                 ITA No.1876/M/2012
                                                       AY : 08-09


was `peppercorn' rent and was payable only if demanded. Thus, the

assessee in that case was not duty bound to pay rent. It was under

these circumstances that the Tribunal held that the assessee had to be

treated as an absolute owner and entitled to exemption under section

54. In the present case, the assessee was bound to pay the rent as

per the agreement and therefore, it could not be considered as

`peppercorn' rent. The case is therefore distinguishable and not

applicable to the facts of the present case.


6.     In view of the foregoing discussion and for the reasons given

earlier, we confirm the order of CIT(A), disallowing the claim of

exemption under section 54 of the Income tax Act.


7.     In the result, the appeal of the assessee is dismissed.


       Order pronounced in the open court on     21.9. 2012.



             Sd/-                                     Sd/-

      ( D.K. AGARWAL)                      (RAJENDRA SINGH)
     JUDICIAL MEMBER                       ACCOUNTANT MEMBER

Mumbai.
Dated : 21.9. 2012
Okk/Jv
                                         19                      ITA No.1876/M/2012
                                                                 AY : 08-09



Copy of the order is forwarded to :
       1.     Assessee as mentioned in the cause title
       2.                      Mumbai.
       3.     CIT-Concerned
       4.     D.R. ITAT `    ' Bench, Mumbai
       5.     Guard File




                                                          By order

                                                     Assistant Registrar
                                                      I.T.A.T, Mumbai.
 
 
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