T.V.RAJAGOPALA RAO
Majety & Sons Oil Co. P. Ltd. – Appellant
Versus
Income-tax Officer – Respondent
1. These are four appeals of the assessee relating to assessment years 1982-83 to 1985-86. They arise out of the orders of the CIT (A) dated 17-2-1988 for assessment years 1982-83 and 1983-84 and dated 30-3-1988 for assessment years 1984-85 and 1985-86.
2. The common question at issue in all these four appeals is one and the same. The said issue is whether the lease income derived from leasing out the mill premises along with plant and machinery is exigible to income-tax under the head 'business income' or under the head 'other sources' as contended by the Department. The events which led to the filing of these appeals. In short are as follows:
(a) Assessee is a private limited company, registered by the Registrar of Companies. Andhra Pradesh, Hyderabad on 2-11-1973. The main objects of Incorporation of the Company was to run cotton ginning and oil extraction mill at Door No. 302/2-A of Dokiparru Village in an area of 2 Acres and 84 Cents of land, The said village is situated under the jurisdiction of Sub-registrar of Narsarao Pet in Guntur District. The factory was built in an area of 2 Acres and 84 Cents of land and it was fitted with all necessary plant and machinery, suffici
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