Income from let out property- Ownership vis-a-vis nature of activity

Hemkunt Chemicals Pvt. Ltd. Vs ITO (ITAT Delhi) To decide nature of income received from letting out of property the deciding factor is not ownership of premises but the nature of activity of assessee and nature of operations in relation thereto. As evident from assessees memorandum, objects of the company were to buy, purchase or otherwise acquire multistoried flats, houses, buildings, etc., and to sell, mortgage, assign, pledge, lease out or otherwise dispose of on installment basis or under hire purchase agreements or in any other manner and to carry on the business of property agents. In t...