1981 (12) TMI 58

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....79 and 1979-80. 2. I have heard the parties. The issue involved in these appeals is regarding relief under section 23(1) in respect of two residential units let out for use otherwise than residence during the accounting periods relevant to the assessment years under appeal. 3. The ITO found that the assessee had constructed six flats in respect of which deduction under section 23(1) was clai....

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....ion 23(1) of the Income-tax Act, 1961 regarding non-residential use of the residential units constructed. A reading of the section shows that the incentive provided by the Parliament was for investment in property for residential purposes during a limited period. But it will be adding to the words in the statute to stretch their meaning to the limit to which the ITO went to hold that only when a r....