SHIELA KAUSHISH vs COMMISSIONER OF INCOME-TAX, DELHI

The Supreme Court held that under Section 23(1) of the Income Tax Act, 1961, the 'annual value' of a building is determined by the standard rent as per the Rent Act, rather than the actual rent received by the landlord. The Court clarified that the actual rent is not the appropriate measure for determining annual value, especially in the absence of a fixed standard rent. The appeals were allowed, overturning the lower authorities' decisions that had relied on the actual rent received.