ACIT v. S. N. Damani Infra Pvt. Ltd. (2022)96 ITR 707 / 211 DTR 105 (Chennai)(Trib)

S. 22 : Income from house property-Main object warehousing and supply-chain solutions-Earning of rental income sans any amenities to tenants-Not an engagement in systematic business activity of letting out properties-Income to be treated as income from house property. [S. 24(a), 28(i)]

The Tribunal held that the assessee’s main object was warehousing and supply chain solutions, which was different from letting out properties on rent. The assessee did not render any amenities to the tenant so as to hold the rental income under the head “Income from business or profession.” The Assessing Officer had not brought on record any evidence to substantiate his view that the assessee was in the business of letting out properties on rental income as a systematic business activity. As a result, such rental income could not be assessed under the head income from business.   (AY.  2014-15)