IN THE HIGH COURT OF DELHI AT NEW DELHI
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ITA 747/2007
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COMMISSIONER OF INCOME TAX ..... Appellant
Through : Ms. P.L. Bansal, Advocate.
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versus
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JITENDRA MOHAN ..... Respondent
Through
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CORAM:
HON'BLE MR. JUSTICE MADAN B. LOKUR
HON'BLE DR. JUSTICE S.MURALIDHAR
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O R D E R
13.08.2007
1. The revenue is aggrieved by an order dated 3rd November, 2006 passed by
the Income Tax Appellate Tribunal, Delhi Bench 'C' in ITA No. 4327/D/2004 for
the Assessment Year 2001-02.
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ITA 747/2007 Page 1 of 3
2. The question that the Revenue seeks to urge in this case is whether the
sale of an industrial shed by the Assessee resulted in a short term capital gain
or a long term capital gain. The Assessee was issued an allotment letter in
respect of an industrial shed by DSIDC. This was sometime in 1994. The
Assessee paid the first instalment immediately on allotment and paid the
subsequent instalments over a period of time ending in 1997. On 18th May, 1998,
the Assessee was put in possession of the industrial shed. The shed was
thereafter sold by the Assessee on 15th December, 2000.
3. In view of this, the Assessing Officer held that the sale of the asset,
that is, the shed resulted in a short term capital gain since the Assessee held
the asset for less than 36 months. The Commissioner of Income Tax (Appeals)
rejected the appeal of the Assessee against this conclusion. However, the
Tribunal allowed the Assessee's further appeal on the ground that the Assessee
was entitled to the asset from the date of allotment. It is against this
decision that the Revenue has filed the present
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appeal.
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ITA 747/2007 Page 2 of 3
4. Even if it is found that the view taken by the Tribunal is incorrect on
the facts of this case, we are of the opinion that it will pertain only to a
single
Assessee and not constitute a general precedent. Therefore, the impugned order
does not raise a substantial question of law.
5. We also find that the tax effect in this case is a little over Rs.1
lakh. It is well below the limit as to tax effect, as determined by the Central
Board of Direct Taxes.
6. The appeal is dismissed.
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MADAN B. LOKUR, J
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S.MURALIDHAR, J
AUGUST 13, 2007
sk
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ITA 747/2007 Page 3 of 3
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