Lease rentals earned by a developer of Software Technology Park should be treated as business income

DCIT v. Golflink Software Park P Ltd. (ITAT Bangalore) – The taxpayer was not only letting out its building for rent, but also carried on a complex commercial activity of setting up a software technology park in which various amenities and fit-outs have been provided. The Tribunal relied on the Supreme Court’s decision of CIT v. National Storage Pvt Ltd [1967] 66 ITR 596 (SC) .  The Tribunal relying on the decision of Global Tech Park P Ltd held that, since the entire activity carried out in an organised manner to earn profit out of the investment made by the taxpayer, it should be tr...