{"id":69622,"date":"1999-09-01T00:00:00","date_gmt":"1999-08-31T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/mysore-minerals-ltd-m-g-road-vs-commissioner-of-income-tax-on-1-september-1999"},"modified":"2017-02-15T20:02:17","modified_gmt":"2017-02-15T14:32:17","slug":"mysore-minerals-ltd-m-g-road-vs-commissioner-of-income-tax-on-1-september-1999","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/mysore-minerals-ltd-m-g-road-vs-commissioner-of-income-tax-on-1-september-1999","title":{"rendered":"Mysore Minerals Ltd., M.G. Road, … vs Commissioner Of Income Tax, … on 1 September, 1999"},"content":{"rendered":"
Supreme Court of India<\/div>\n
Mysore Minerals Ltd., M.G. Road, … vs Commissioner Of Income Tax, … on 1 September, 1999<\/div>\n
Author: R C Lahoti<\/div>\n
Bench: S. Rajendra Babu, R.C. Lahoti<\/div>\n
           CASE NO.:\nAppeal (civil)  5374 of 1994\n\nPETITIONER:\nMYSORE MINERALS LTD., M.G. ROAD, BANGALORE\n\nRESPONDENT:\nCOMMISSIONER OF INCOME TAX, KARNATAKA, BANGALORE\n\nDATE OF JUDGMENT: 01\/09\/1999\n\nBENCH:\nS. RAJENDRA BABU & R.C. LAHOTI\n\nJUDGMENT:\n<\/pre>\n
JUDGMENT<\/p>\n
1999 (1) Supp. SCR 192<\/p>\n
The Judgment was delivered by R. C. LAHOTI J.\n<\/p>\n
R. C. LAHOTI J.\n<\/p>\n
The appellant-assessee is a private limited company. During the assessment
\nyear 1981-82 (accounting year ending on March 31, 1981), the assessee had
\npurchased for the use of its staff seven low income group houses from the
\nHousing Board. The assessee had made part payments and was in turn made
\nallotment of the houses followed by delivery of possession by the Housing
\nBoard. The actual deed of conveyance was not yet executed by the Housing
\nBoard in favour of the assessee. The assessee made a claim under section 32
\nof the Income-tax Act, 1961, in respect of depreciation of buildings used
\nfor the purpose of the business of the assessee, The claim was rejected by
\nthe Assessing Officer forming an opinion that the assessee had not become
\nowner for want of deed of conveyance in its favour. The Commissioner of
\nIncome-tax allowed the appeal preferred by the assessee and directed the
\nAssessing Officer to allow the assessee’s claim for depreciation inasmuch
\nas the company was acting as the owner and could exercise the rights of the
\nowner qua the houses. The Tribunal in an appeal preferred by the Revenue
\nset aside the decision of the Commissioner of Income-tax. On an application
\nunder section 256(1) of the Act filed by the appellant, the following
\nquestion was referred by the Tribunal for the opinion of the High Court<\/p>\n
    “Whether, on the facts and in the circumstances of the case, the
\n    Tribunal was right in rejecting the claim of the assessee for
\n    depreciation in respect of the seven houses in respect of which the
\n    assessee has not obtained a deed for conveyance from the vendor
\n    although it had taken possession and made part payment of the
\n    consideration ?”\n<\/p>\n
The High Court relying on its own decision in Ramkumar Mills P. Ltd. v. CIT<\/a>
\n1989 (180) ITR 464, answered the question in the affirmative, that is,
\nagainst the assessee. The aggrieved assessee has preferred this appeal
\npursuant to a certificate under section 261 of the Act granted by the High
\nCourtSection 32 of the Act allows certain deductions, one of them being
\ndepreciation of buildings, etc., owned by the assessee and used for the
\npurposes of the business or profession. It is the word “owned” as occurring
\nin sub-section (1) of section 32 which is the core of controversy. Is it
\nonly an absolute owner or an owner of the asset as understood in its legal
\nsense who can claim depreciation ? Or, a vesting of title short of full-
\nfledged or legal ownership can also entitle an assessee to claim
\ndepreciation under section 32 ? Learned senior counsel for the Revenue has
\nsubmitted-that the term “owned” should be assigned its legal meaning and so
\nlong as an assessee has not become an owner of the property in the sense
\nthat the title has not come to vest in him in the manner contemplated by
\nlaw, he cannot claim benefit of deduction under section 32 of the Act.
\nUnder section 54 of the Transfer of Property Act, title in immovable
\nproperty is transferred to a person by execution and registration of a sale
\ndeed. Admittedly, that having not taken place, the assessee is not entitled
\nto the benefit. Learned counsel for the assessee has on the other hand
\nplacing reliance on the decisions of this court in R. B. Jodha Mal Kuthiala
\nv. CIT 1971 (82) ITR 570 and CIT v. Podar Cement Pvt. Ltd. 1997 (226) ITR
\n625, submitted that the term “owned” in section 32(1) should be assigned a
\ncontextual meaning and keeping in view the underlying object of the
\nprovision vesting of a title in the assessee though short of absolute
\nownership should also entitle the assessee to the benefit of section 32(1)<\/p>\n
Section 32 of the Income-tax Act confers a benefit on the assessee. The
\nprovision should be so interpreted and the words used therein should be
\nassigned such meaning as would enable the assessee securing the benefit
\nintended to be given by the Legislature to the assessee. It is also well-
\nsettled that where there are two possible interpretations of a taxing
\nprovision the one which is favourable to the assessee should be
\npreferredWhat is ownership ? The terms “own”, ” ownership”, “owned”, are
\ngeneric and relative terms. They have a wide and also a narrow connotation,
\nThe meaning would depend on the context in which the terms are used Black’s
\nLaw Dictionary (6th edition), defines “owner” as under<\/p>\n
    “Owner, The person in whom is vested the ownership, dominion, or title
\n    of property ; proprietor. He who has dominion of a thing, real or
\n    personal, corporeal or incorporeal, which he has a right to enjoy and
\n    do with as he pleases, even to spoil or destroy it, as far as the law
\n    permits, unless he be prevented by some agreement or covenant which
\n    restrains his right<\/p>\n
    The term is, however, a nomen generalissimum, and its meaning is to be
\n    gathered from the connection in which it is used, and from the subject-
\n    matter to which it is applied. The primary meaning of the word as
\n    applied to land is one who owns the fee and who has the right to
\n    dispose of the property, but the term also includes one having a
\n    possessory right to land or the person occupying or cultivating it<\/p>\n
    The term ‘owner’ is used to indicate a person in whom one or more
\n    interests are vested for his own benefit . . . .”\n<\/p>\n
    In the same dictionary, the term” ownership”has been defined to mean,
\n    inter alia, a” collection of rights to use and enjoy property,
\n    including right to transmit it to others …. The right of one or more
\n    persons to possess and use a thing to the exclusion of others. The
\n    right by which a thing belongs to some one in particular, to the
\n    exclusion of all other persons. The exclusive right of possession,
\n    enjoyment and disposal ; involving as an essential attribute the right
\n    to control, handle, and dispose.”\n<\/p>\n
    Dias on Jurisprudence (4th edition, at page 400) states<\/p>\n
    ” The position, therefore, seems to be that the idea of ownership of
\n    land is essentially one of the ‘better right’ to be in possession and
\n    to obtain it, whereas, with chattels the concept is a more absolute
\n    one. Actual possession implies a right to retain it until the contrary
\n    is proved, and to that extent a possessor is presumed to be owner.”\n<\/p>\n
Stroud’s Judicial Dictionary gives several definitions and illustrations of
\nownership. One such definition is that the “owner” or “proprietor” of a
\nproperty is the person in whom (with his or her assent) it is for the time
\nbeing beneficially vested, and who has the occupation, or control, or
\nusefruct, of it ; e.g., a lessee is, during the term, the owner of the
\nproperty demised. Yet another definition that has been given by Stroud is<\/p>\n
    “‘Owner’ applies ‘to every person in possession or receipt either of
\n    the whole, or of any part, of the rents or profits of any land or
\n    tenement ; or in the occupation of such land or tenement, other than as
\n    a tenant from year to year or for any less term or as a tenant at
\n    will’.”\n<\/p>\n
In State of U. P. v. Renusagar Power Company<\/a> 1991 (70) CC 127, 149 (SC) is,
\nwas held that<\/p>\n
    “the word ‘own’ is a generic term, embracing within itself several
\n    gradations of title, dependent on the circumstances, and it does not
\n    necessarily mean ownership in fee simple ; it means, ‘to possess, to
\n    have or hold as property'”\n<\/p>\n
In CIT v. Podar Cement Pvt. Ltd. 1997 (226) ITR 625 (SC), the question
\nwhich came up for consideration before this court was whether the rental
\nincome from the house property which had come to vest in the assessee, but
\nas to which the assessee was not legal owner for want of deed of title, was
\nliable to be assessed as income from house property or as income from other
\nsources. To be assessable as income from house property within the meaning
\nof section 22 of the Act the property should be such “of which the assessee
\nis the owner”. This court upon a juristic analysis of the underlying scheme
\nof the Act and resorting to contextual and purposive interpretation, also
\nhaving reviewed several conflicting decisions of different High Courts,
\nheld that the liability to be assessed was fixed on a person who receives
\nor is entitled to receive the income from the property in his own right.
\nVide para. 55, this court has held<\/p>\n
    “We are conscious of the settled position that under the common law,
\n    ‘owner’ means a person who has got valid title legally conveyed to him
\n    after complying with the requirements of law such as the Transfer of
\n    Property Act, Registration Act, etc. But, in the context of section 22
\n    of the Income-tax Act, having regard to the ground realities and
\n    further having regard to the object of the Income-tax Act, namely, ‘to
\n    tax the income’, we are of the view, ‘owner’ is a person who is
\n    entitled to receive income from the property in his own right.”\n<\/p>\n
In R. B. Jodha Mal Kuthiala v. CIT 1971 (82) ITR 570 (SC), it was held for
\nthe purpose of section 9 of the Indian Income-Tax Act, 1922, that the owner
\nmust be the person who can exercise the rights of the owner, not on behalf
\nof the owner but in his own right<\/p>\n
We may usefully extract and reproduce the following classic statement of
\nlaw from Perry v. Clissold [1907] A.C. 73 (PC) quoted with approval in Nair
\nService Society Ltd. v. K. C. Alexander,<\/a> 1968 AIR(SC) 1165<\/p>\n
    “It cannot be disputed that a person in possession of land in the
\n    assumed character of owner and exercising peaceably the ordinary rights
\n    of ownership has a perfectly good title against all the world but the
\n    rightful owner. And if the rightful owner does not come forward and
\n    assert his title by the process of law within the period prescribed by
\n    the provisions of the statute of limitation applicable to the case, his
\n    right is for ever extinguished and the possessory owner acquires an
\n    absolute title.”\n<\/p>\n
Podar Cement’s case 1997 (226) ITR 625 (SC), is under the Income-tax Act
\nand has to be taken as a trend-setter in the concept of ownership.
\nAssistance from the law laid down therein can be taken for finding out the
\nmeaning of the term “owned” as occurring in section 32(1) of the ActIn our
\nopinion, the term “owned” as occurring in section 32(1) of the Income-tax
\nAct, 1961, must be assigned a wider meaning. Anyone in possession of
\nproperty in his own title exercising such dominion over the property as
\nwould enable others being excluded therefrom and having the right to use
\nand occupy the property and\/or to enjoy its usufruct in his own right would
\nbe the owner of the buildings though a formal deed of title may not have
\nbeen executed and registered as contemplated by the Transfer of Property
\nAct, the Registration Act, etc. “Building owned by the assessee” the
\nexpression as occurring in section 32(1) of the Income-tax Act means the
\nperson who having acquired possession over the building in his own right
\nuses the same for the purposes of the business or profession though a legal
\ntitle has not been conveyed to him consistently with the requirements of
\nlaws such as the Transfer of Property Act and the Registration Act, etc.,
\nbut nevertheless is entitled to hold the property to the exclusion of all
\nothers<\/p>\n
Generally speaking depreciation is an allowance for the diminution in the
\nvalue due to wear and tear of a capital asset employed by an assessee in
\nhis business. Black’s Law Dictionary (fifth edition) defined depreciation
\nto mean, inter alia<\/p>\n
    “A fall in value ; reduction of worth. The deterioration, or the loss
\n    or lessening in value, arising from age, use, and improvements, due to
\n    better methods. A decline in value of property caused by wear or
\n    obsolescence and is usually measured by a set formula which reflects
\n    these elements over a given period of useful life of property ….
\n    Consistent, gradual process of estimating and allocating cost of
\n    capital investments over estimated useful life of asset in order to
\n    match cost against earnings . . .”\n<\/p>\n
Parks in Principles and Practice of Valuation (fifth edition, at page 323)
\nstates : As for building, depreciation is the measurement of wearing out
\nthrough consumption, or use, or effluxion of time. Paton has in his
\nAccount’s Handbook (third edition) observed that depreciation is an out of
\npocket cost as any other costs. He has further observed—the depreciation
\ncharge is merely the periodic operating aspect of fixed asset costs<\/p>\n
In Badiani P. K. v. CIT<\/a> 1976 (105) ITR 642, the Supreme Court has observed
\nthat allowance for depreciation is to replace the value of an asset to the
\nextent it has depreciated during the period of accounting relevant to the
\nassessment year and as the value has, to that extent, been lost, the
\ncorresponding allowance for depreciation takes place<\/p>\n
An overall view of the above said authorities shows that the very concept
\nof depreciation suggests that the tax benefit on account of depreciation
\nlegitimately belongs to one who has invested in the capital asset, is
\nutilizing the capital asset and thereby losing gradually investment caused
\nby wear and tear, and would need to replace the same by having lost its
\nvalue fully over a period of time<\/p>\n
It is well-settled that there cannot be two owners of the property
\nsimultaneously and in the same sense of the term. The intention of the
\nLegislature in enacting section 32 of the Act would be best fulfilled by
\nallowing deduction in respect of depreciation to the person in whom for the
\ntime being vests the dominion over the building and who is entitled to use
\nit in his own right and is using the same for the purposes of his business
\nor profession. Assigning any different meaning would not subserve the
\nlegislative intent. To take the case at hand it is the appellant-assessee
\nwho having paid part of the price, has been placed in possession of the
\nhouses as an owner and is using the buildings, for the purpose of its
\nbusiness in its own right. Still the assessee has been denied the benefit
\nof section 32. On the other hand, the Housing Board would be denied the
\nbenefit of section 32 because in spite of its being the legal owner it was
\nnot using the building for its business or profession. We do not think such
\na benefit-to-none situation could have been intended by the Legislature.
\nThe finding of fact arrived at in the case at hand’ is that though a
\ndocument of title was not executed by the Housing Board in favour of the
\nassessee, but the houses were allotted to the assessee by the Housing
\nBoard, part payment received and possession delivered so as to confer
\ndominion over the property on the assessee whereafter the assessee had in
\nits own right allotted the quarters to the staff and they were being
\nactually used by the staff of the assessee. It is common knowledge, under
\nthe various schemes floated by bodies like housing boards, houses are
\nconstructed on a large scale and allotted on part payment to those who have
\nbooked. Possession is also delivered to the allottee so as to enable
\nenjoyment of the property. Execution of documents transferring title
\nnecessarily follows if the schedule of payment is observed by the allottee.
\nIf only the allottee may default the property may revert back to the Board.
\nThat is a matter only between the Housing Board and the allottee. No third
\nperson intervenes. The part payments made by allottee are with the
\nintention of acquiring title. The delivery of possession by the Housing
\nBoard to the allottee is also a step towards conferring ownership.
\nDocumentation is delayed only with the idea of compelling the allottee to
\nobserve the schedule of paymentFor the foregoing reasons, in our opinion,
\nthe High Court was not right in taking the view which it did. The appeal is
\nallowed. The judgment of the High Court is set aside. The question referred
\nby the Tribunal to the High Court is answered in the negative, that is,
\nagainst the Revenue and in favour of the assessee. No order as to costs<\/p>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India Mysore Minerals Ltd., M.G. Road, … vs Commissioner Of Income Tax, … on 1 September, 1999 Author: R C Lahoti Bench: S. Rajendra Babu, R.C. Lahoti CASE NO.: Appeal (civil) 5374 of 1994 PETITIONER: MYSORE MINERALS LTD., M.G. ROAD, BANGALORE RESPONDENT: COMMISSIONER OF INCOME TAX, KARNATAKA, BANGALORE DATE OF JUDGMENT: 01\/09\/1999 […]<\/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":[30],"tags":[],"class_list":["post-69622","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nMysore Minerals Ltd., M.G. 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