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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether capital gains arising from the sale of a portion of land forming part of the compound of an official residence of a Ruler of an Indian State were exempt from tax under paragraph 15(1)(iii) of the Part B States (Taxation Concessions) Order, 1950.
Analysis: Paragraph 15(1)(iii) exempts only the bona fide annual value of the palaces of Rulers of Indian States declared by the Central Government as official residences. The provision does not extend to income in the nature of capital gains arising from the sale of land forming part of such residence. The exemption clause was therefore confined to annual value and could not be expanded to cover capital gains.
Conclusion: The capital gains realised on the sale of the land were not entitled to exemption under paragraph 15(1)(iii) of the Part B States (Taxation Concessions) Order, 1950, and the answer was against the assessee.
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