{"id":211136,"date":"2002-05-28T00:00:00","date_gmt":"2002-05-27T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-deep-chand-on-28-may-2002"},"modified":"2015-07-12T12:24:54","modified_gmt":"2015-07-12T06:54:54","slug":"commissioner-of-income-tax-vs-deep-chand-on-28-may-2002","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-deep-chand-on-28-may-2002","title":{"rendered":"Commissioner Of Income-Tax, … vs Deep Chand on 28 May, 2002"},"content":{"rendered":"
Delhi High Court<\/div>\n
Commissioner Of Income-Tax, … vs Deep Chand on 28 May, 2002<\/div>\n
Author: S Sinha<\/div>\n
Bench: S Sinha, A Sikri<\/div>\n<\/p>\n
<\/pre>\n
JUDGMENT<\/p>\n
S.B. Sinha, C.J. <\/p>\n
 1. These references at the instance of the Revenue have been
\nmade under Section 256(1) of the Income Tax Act, 1961 (
\nhereinafter referred to as ‘the Act’) by the Income-tax
\nAppellate Tribunal, Delhi Bench ‘A’, Delhi (hereinafter
\nreferred to as ‘the Tribunal’), for the opinion of this Court
\non the following question :-\n<\/p>\n
  “Whether, on the facts and in the
\ncircumstances of the case, capital gains
\narising on transfer of agricultural lands in
\nvillage Nangal Dewat, Delhi is chargeable to
\ntax?”\n<\/p>\n
 2. The basic fact of the matter is not in dispute.\n<\/p>\n
  FACTS OF ITR NO. 478 OF 1983 :-\n<\/p>\n
 2.1 The petitioner possessed 154 bighas of agricultural land in
\nVillage Nangal Dewat, which is located near Delhi-Najafgarh
\nRoad adjoining Palam Airport. The said land was acquired
\nby the Government for extension of the Palam Airport vide
\nnotification dated 03.12.1971 purported to be issued under
\nSection 4 of the Land Acquisition Act. A sum of
\nRs. 8,55,450\/- by way of compensation was awarded to the
\npetitioner by the Land Acquisition Officer vide his order
\ndated 20.07.1973 where after possession of the said land
\nwas also taken over by the Government. However, the
\npetitioner did not declare any income under the head
\n‘Capital Gains’ on the ground that the agricultural land
\nowned by him was not a capital asset within the meaning of
\nSection 2(14) of the Act and, thus, the transfer did not
\nresult in capital gains.\n<\/p>\n
 2.2 The Income Tax Officer (in short, ‘the ITO’), however, did
\nnot accept his submission and held that the said land was
\nsituated within the jurisdiction of Municipal Corporation of
\nDelhi and by virtue of amendment made in the definition of
\n‘Capital Asset’ w.e.f. 01.04.1970, the same became a capital
\nasset, at the hands of the assessed. It was also noticed by
\nthe ITO that the petitioner had not accepted the award of
\nthe Land Acquisition Officer and filed appeals there against
\nbefore the Additional District Session Judge claiming
\ncompensation @ Rs. 40,000\/- per bigha. Therefore, he took
\nthe view that the fair market value of the said land
\ntransferred by the petitioner as on the date of transfer
\nexceeded the full value of consideration declared by the
\npetitioner in respect of the transfer by more than 15% to the
\nvalue declared and, on the said basis held that the
\nprovisions of Section 52(2) were applicable in the case of the
\npetitioner. Thereafter, he sought for and obtained approval
\nof the Inspecting Assistant Commissioner of Income-tax,
\nRange – V(B), New Delhi (in short, ‘IAC’) for substituting
\nthe consideration of the transferred which was fixed by the
\nITO at Rs. 61,60,000\/-. The ITO estimated the value of the
\nland at Rs. 2,31,000\/- as on 01.01.1954, whereas the
\nassessed claimed that the value of the said land as on
\n01.01.1954 was liable to be worked out by applying a rate of
\nRs. 3,500\/- per bigha, but could not support his submission
\nin respect thereof. The ITO rejected the assessed’s plea on
\nthe ground that the value of agricultural land in 1954 in the
\nvillages of Delhi was very low and held that the market value
\nof the property as on 01.05.1954 was Rs.1,500\/- per bigha.
\nIt was also contended by the assessed before the ITO that he
\nhad expended Rs. 35,000\/- on the improvement of land,
\nwhereas the ITO curtailed the said claim on the ground that
\nonly a little evidence was led in support thereof and
\ndetermined the capital gains arising to the petitioner at
\nRs. 36,05,117\/- as against ‘Nil’ as declared by him.\n<\/p>\n
 2.3 As the variation in the income was more than Rs. 1,00,000\/-
\nthe ITO forwarded a draft of the proposed order of
\nassessment to the assessed. There against several objections
\nwere made.\n<\/p>\n
 2.4 The proposed order along with the objections received was
\nforwarded to the IAC by the Assessing Officer, who after
\ngiving an opportunity to the assessed, issued directions to
\nthe ITO. The ITO thereafter incorporated the said directions
\nand determined the income of the appellant at
\nRs. 36,25,366\/-.\n<\/p>\n
 2.5 Aggrieved by and dissatisfied with the aforesaid order, the
\nassessed preferred an appeal before the Appellate Assistant
\nCommissioner (in short, ‘the AAC’), which was allowed in
\npart.\n<\/p>\n
 The assessed again preferred an appeal before the Tribunal,
\nwhich was allowed by the Tribunal.\n<\/p>\n
 2.6 On being moved for reference, the question, as set out
\nabove, has been referred for opinion of this Court.\n<\/p>\n
 We need not to go in great details of the facts of I.T.R. No.
\n479 of 1983, as the same are almost identical to I.T.R. No.
\n478 of 1983.\n<\/p>\n
 3. Section 2(14)(iii) of the Act reads thus :-\n<\/p>\n
 “(14) “capital asset” means property of any
\nkind held by an assessed, whether or not
\nconnected with his business or profession, but
\ndoes not include –\n<\/p>\n
 … … … … … … …\n<\/p>\n
 (iii) agricultural land in India, not being land
\nsituate –\n<\/p>\n
 (a) in any area which is comprised within
\nthe jurisdiction of a municipality
\n(whether known as a municipality,
\nmunicipal corporation, notified area
\ncommittee, town area committee, town
\ncommittee, or by any other name) or a
\ncantonment board and which has a
\npopulation of not less than ten thousand
\naccording to the last preceding census of
\nwhich the relevant figures have been
\npublished before the first day of the
\nprevious year; or  <\/p>\n
 (b) in any area within such distance, not
\nbeing more than eight kilometres, from
\nthe local limits of any municipality or
\ncantonment board referred to in item (a),
\nas the Central Government may, having
\nregard to the extent of, and scope for,
\nurbanization of that area and other
\nrelevant considerations, specify in this
\nbehalf by notification in the official
\nGazette;”\n<\/p>\n
 The aforesaid provision, in our opinion, is absolutely clear
\nand unambiguous.\n<\/p>\n
 3.1 A bare perusal of the aforementioned provision would
\nclearly go to show that ‘capital assets’ means property of
\nand kind held by an assessed, whether or not connected
\nwith his business or profession, but does not include any
\nstock-in-trade, consumable stores or raw materials held for
\nthe purpose of his business or profession; and personal
\neffects, that is to say, movable property (including wearing
\napparel and furniture, but excluding jewellery) held for
\npersonal use by the assessed or any member of his family
\ndependent on him.\n<\/p>\n
 6.3.2 It may be true that the expression used therein is not very
\nhappy and could have been more explicit, but in terms
\nthereof if the land is situated in an area, which is comprised
\nwithin the jurisdiction of a municipality and has a
\npopulation of not less than 10,000. The land must be
\nsituated in a municipality or a cantonment board. Had the
\nintention of the law-maker been that the land situated in a
\nvillage of not less than 10,000 will come within the purview
\nof Section 14(1)(iii) of the Act, there was no reason as to why
\nthe same could not have been explicity stated in the
\nstatute.\n<\/p>\n
 3.3. It is now a well settled principle of law that a literal meaning
\nshould be attributed to a statute. The golden rule of
\ninterpretation should ordinarily be adhered to.\n<\/p>\n
 3.4 In  Gurudevdatta Vksss Maryadit & Ors. v. State of
\nMaharashtra & Ors.,<\/a>  it has been held :-\n<\/p>\n
  “It is cardinal principle of interpretation of
\nstatute that the words of a statute must be understood
\nin their natural, ordinary or popular sense and
\nconstrued according to their grammatical meaning,
\nunless such construction leads to some absurdity or
\nunless there is something in the context or in the
\nobject of the statute to suggest to the contrary. The
\ngolden rule is that the words of a statute must prima
\nfacie be given their ordinary meaning. It is yet
\nanother rule of construction that when the words of
\nthe statute are clear, plain and unambiguous, then the
\ncourts are bound to give effect to that meaning,
\nirrespective of the consequences. It is said that the
\nwords themselves best declare the intention of the
\nlaw-giver. The courts have adhered to the principle
\nthat efforts should be made to give meaning to each
\nand every word used by the legislature and it is not a
\nsound principle of construction to brush aside words
\nin a statute as being inapposite surpluses, if they can
\nhave a proper application in circumstances
\nconceivable within the contemplation of the statute.”\n<\/p>\n
 The said principle was reiterated in   Harshad S. Mehta &
\nOrs. v. State of Maharashtra<\/a>   ,  and   Dental Council of India &
\nAnr. v. Hari Prakash & Ors.<\/a>  ,  <\/p>\n
 3.5. Yet again in   Dadi Jagannadham v. Jammulu Ramulu &
\nOrs.<\/a> , AIR 2001 SCW 3051 the Court referred to   P.K. Unni v. Nrimala Industries<\/a>   ,  in the following lines :-\n<\/p>\n
 “15. The court must indeed proceed on the
\nassumption that the legislature did not make a
\nmistake and that it intended to say what it said
\n: See  Nalinakhya Bysack v. Shyam Sunder
\nHaldar<\/a>   ,  . Assuming there is a defect or
\nan omission in the words used by the
\nLegislature, the Court would not go to its aid to
\ncorrect or make up the deficiency. The Court
\ncannot add words to a statute or read words
\ninto it which are not there, especially when the
\nliteral reading producers an intelligible result.
\nNo cause can be found to authorise any Court
\nto alter a word so as to produce a casus
\nomissus : Per Lord Halsbury,   Mersey Docks
\nand Harbour Board v. Henderson Brothers
\n (1888) 13 AC 595, 602: 4 TLR 703) .\n<\/p>\n
 “We cannot aid the legislature’s defective
\nphrasing of an Act, we cannot add and mend,
\nand, by construction, make up deficiencies
\nwhich are left there”:   Crawford v. Spooner
\n (1846) 6 Moore PC 1, 8, 9 : 4 Moo Ind App
\n179   .\n<\/p>\n
 16. Where the language of the statute leads
\nto manifest contradiction of the apparent
\npurpose of the enactment, the Court can, of
\ncourse, adopt a construction which will carry
\nout the obvious intention of the legislature. In
\ndoing so ” a Judge must not alter the material
\nof which the Act is women, but he can and
\nshould iron out the creases.” : Per Denning,
\nL.J., as he then was,   Seaford Court Estates
\nLtd. v. Asher     (1949) 2 All E R 155, 164  . See
\nthe observation of Sarkar, J. in   M. Pentiah v.\n<\/p>\n
Muddala Veeramallappa    .”\n<\/p>\n
 3.6. The question referred to this court for its opinion is no
\nlonger res integra in view of the decision of the Madras High
\nCourt in   S. Hidhayathullah Sahib v. Commissioner of Income-
\nTax  , (1986) 158 ITR 20 wherein it was held :-\n<\/p>\n
  “The section lays down two criteria: (1)
\nthat the agricultural land should be in an area
\nwithin the municipality; and (2) that the area
\nshould have a population of more than 10,000.
\nThe expression “which has a population of not
\nless than ten thousand according to the last
\npreceding census” is intended to qualify only
\nthe “area” and not the “municipality”.
\nHowever, it is not possible to go only by the
\nlanguage used in that provision without having
\nregard to the object and intendment of the
\nprovision. If the Legislature meant to fix a
\nminimum limit of population for any area
\nwithin a municipality or cantonment Board, it
\nwould have specified a particular area such as
\nvillage, ward, street, etc., and since the
\nLegislature has left the area in a municipality
\nundefined, it would not have prescribed a limit
\nof population for such an unspecified or
\nindefinite area within a municipality. It may be
\nthat a municipality may comprise of many
\nvillages, wares and streets and each assessed
\nmay claim that the limit of population is
\nprovided with reference to a village, ward or
\nstreet. In such an event, the section will have
\nno uniform application and will lead to many
\nanomalies. Therefore, it is necessary to avoid
\nsuch an interpretation of the section which
\nleads to anomalies and which will make it
\ninvalid. We have to adopt such a construction
\nwhich will make the section valid and certain.”\n<\/p>\n
 Approving the aforesaid decision of the Madras High Court,
\nthe Apex Court in   G.M. Omer Khan v. Commissioner of
\nIncome Tax (Addl.)<\/a> , (1992) 196 ITR 269 held :-\n<\/p>\n
  “This, in our view, is the correct position
\nand has aptly and pithily been put. Nothing
\nmore is needed to be said on the subject. The
\ninterpretation put by the High Court on the
\nprovisions appears to us to be unexceptionable
\nand rational. We affirm that interpretation.”\n<\/p>\n
 3.7. This aspect of the matter has also been considered by a
\nDivision Bench of this Court in   Commissioner of Income Tax
\nv. Pyare Lal   , (1998) 231 ITR 785.\n<\/p>\n
 The question involved herein is also covered by an
\nunreported decision passed in ITR Nos. 184 & 185 of 1982,
\nwherein Lahoti J., as his lordship then was, by a judgment
\nand order dated 31.07.1997 held :-\n<\/p>\n
 “The first question is covered by the
\ndecision of the Supreme Court in   G.M. Omer
\nKhan v. CIT    196 ITR 269   approving the
\ndecision of Madras High Court in   S.\n<\/p>\n
Hidayatullah Sachil v. CIT    (1986) 158 ITR 20
\nwherein it has been held that population of the
\nMunicipality is to be taken into account for the
\npurpose of Section 2(14)(iii)(a) and not the
\npopulation in any area within the jurisdiction
\nof Municipality.\n<\/p>\n
 The second question has to be answered
\nin the light of the amendments made in the
\ndefinition of ‘Agricultural income’ in Clause
\n1(A) of Section 2 and the definition of ‘Capital
\nasset’ in Clause 14 of Section 2 incorporated
\nrespectively by the Finance Act, 1989 and the
\nFinance Act, 1970 with retrospective effect
\nfrom 1.4.1970.\n<\/p>\n
 Accordingly, both the questions are
\nanswered in the negative i.e. in favor of the
\nRevenue and against the assessed.”\n<\/p>\n
 4. In this view of the matter, the question is answered in the negative, i.e., in favor of the Revenue and against the assessed. However, in the facts and circumstances of the case, there shall be no order as to costs.<\/p>\n","protected":false},"excerpt":{"rendered":"
Delhi High Court Commissioner Of Income-Tax, … vs Deep Chand on 28 May, 2002 Author: S Sinha Bench: S Sinha, A Sikri JUDGMENT S.B. Sinha, C.J. 1. These references at the instance of the Revenue have been made under Section 256(1) of the Income Tax Act, 1961 ( hereinafter referred to as ‘the Act’) by […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[14,8],"tags":[],"class_list":["post-211136","post","type-post","status-publish","format-standard","hentry","category-delhi-high-court","category-high-court"],"yoast_head":"\nCommissioner Of Income-Tax, ... vs Deep Chand on 28 May, 2002 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/commissioner-of-income-tax-vs-deep-chand-on-28-may-2002\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"Commissioner Of Income-Tax, ... vs Deep Chand on 28 May, 2002 - 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