https://www.taxtmi.com/caselaws?id=78691 A lease deed granting nine years with a further nine years by extension or renewal was treated as falling within the deeming provision in the Explanation to Section 269UA(f)(i) of the Income-tax Act, 1961. The deed had to be read as a whole: one clause made the further term optional at the lessee's instance, and another contemplated renewal on specified conditions. On that combined reading, the lease provided for extension and the aggregate term exceeded twelve years, so Chapter XXC applied. Strict construction of penal statutes did not assist, because the issue was the true construction of the lease deed rather than a narrow reading of the Explanation. en-us Tue, 07 Dec 2010 00:00:00 +0530 Tue, 26 Sep 2017 12:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=78691 A lease deed granting nine years with a further nine years by extension or renewal was treated as falling within the deeming provision in the Explanation to Section 269UA(f)(i) of the Income-tax Act, 1961. The deed had to be read as a whole: one clause made the further term optional at the lessee's instance, and another contemplated renewal on specified conditions. On that combined reading, the lease provided for extension and the aggregate term exceeded twelve years, so Chapter XXC applied. Strict construction of penal statutes did not assist, because the issue was the true construction of the lease deed rather than a narrow reading of the Explanation. Case-Laws Income Tax Tue, 07 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=78691