RVM Education (P.) Ltd. v. ACIT (2023)102 ITR 31 (SN)(Delhi) (Trib)

S. 22 : Income from house property-Business income-Receipts under leave and licence agreement taxable as income from house property-Income from consultancy treated as business income. [S.28(i)]

Dismissing the appeal, that on the strength of the two main objects of the assessee income from consultancy had been treated as business income of the assessee. These objects were vague and general in nature and could not justify bifurcation of the revenue from operations into two parts namely rental income and consultancy services fees. There was no error or infirmity in the findings of the Commissioner (Appeals).(AY.2016-17)