Dismissing the appeal of the revenue the Court held that  the assessee was obligated to work under a statutory approved scheme; the lease of eight years was to ATL, which was in the same business and the lease was for utilising the plant, machinery, etc. for manufacturing tyres; the actuals were reimbursed to assessee by ATL; the work force of the assessee had been deployed for manufacturing tyres; the total production from the assessee unit was taken over by ATL; over all affairs of assessee company were made viable by entering into settlement; coupled with all other primary circumstances, the assessee employed commercial assets to earn income. The scheme was for providing a solution to the business problem of the assessee. The claim of lease rental receipt as income of business was justifiable for the assessment years. (AY.1996-97 to 2003-04)