Repairs deduction under house-property income is confined to the statute's express categories; no cumulative allowance for mixed lease obligations.

A deduction for repairs in house-property income is available only within the statutory situations expressly covered by section 24(1)(i), namely where the owner or the tenant bears the repair cost. Where both landlord and tenants assume repair obligations under the lease deeds, the provision does not permit a cumulative deduction, and any gap in the language cannot be filled by judicial interpretation. The computation of income from house property remains a notional exercise, so deductions must stay within the statutory wording. On the facts discussed, the claimed repair deduction was not allowable.

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Issues: Whether the assessee was entitled to deduction for repairs under section 24(1)(i) of the Income-tax Act, 1961, where both the landlord and the tenants had undertaken obligations relating to repairs under the lease deeds.

Analysis: The deduction for repairs under section 24(1)(i) is structured only for the situations expressly covered by the provision, namely, where the owner has undertaken to bear the cost of repairs or where the tenant has undertaken to bear that cost. On the facts, both the assessee and the tenants had assumed repair obligations, so the case did not fit neatly within either clause (a) or clause (b). The Tribunal held that the provision did not contemplate a cumulative deduction in such a situation and that the omission could not be supplied by judicial interpretation. The computation of income from house property is a notional one, and the deductions allowed under the section cannot be extended beyond the statutory language.

Conclusion: The assessee was not entitled to the claimed deduction for repairs, and the disallowance was upheld against the assessee.

Final Conclusion: The appeal failed because the statutory scheme for house-property deductions did not permit the claimed allowance on the facts found.

Ratio Decidendi: A deduction under section 24(1)(i) for repairs can be allowed only within the situations expressly provided by the statute, and where the facts fall outside those categories, the court cannot supply the omission by interpretation.

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