Assessee earned rental income from the warehousing activities and treated the same as business income and claimed expenditure against the same. However, Ld. AO treated the same as Income from House Property and disallowed the expenditure claimed by the assessee against earning of such income. On appeal, CIT (A) treated the rental income as business income Aggrieved by the order of CIT (A), Revenue filed an appeal before ITAT. The Tribunal dismissed department appeal following the earlier year’s order, wherein it was observed that the assessee is not merely letting out its premises for warehousing but were doing complex commercial activity. All the duties cast upon the assessee was responsible for ensuring the incoming and, outgoing of goods apart from providing adequate security. The consideration received by the assessee from client is not for letting the property on rental basis but the consideration received is exclusively for providing the benefits of business service facilities to the client. The customer had no right of occupancy and the assessee had control of the premises. The Tribunal held that as assessee provided round the clock service to the clients from various aspects from letting out of goods, their security etc., rental income will definitely fall within the purview of business income. (ITA No. 380/Mum/2017 & ITA No.7556/Mum/2016,  dt.19.12.2018, AY 2012-13)