If company constructed structure on shareholders land then rent there from will be taxable in the hand of company

RELEVANT PARAGRAPH In so far as the rents received from “Samsung” are concerned., the finding recorded by the Assessing Officer is that, the structure is constructed by the Company itself with its own funds and not that the super structure has been constructed by the shareholders on the land belonging to the Company or a case where the investments have been made on behalf of the shareholders. Therefore, the only conclusion is that not only does the Company exercise all such rights as that of the owner, but also the rental income, notwithstanding the fact that in terms of the memora...